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Document Productions Privileged Communication

EDRM - Electronic Discovery Reference Model

[Webinar] Important eDiscovery Case Law Decisions for February 2025 - February 25th, 1:00 pm - 2:00 pm ET

It’s the season of love – for eDiscovery case law! In our February 2025 monthly webinar of cases covered by the eDiscovery Today blog we will discuss disputes related to cross-border disputes and the Hague Convention,...more

EDRM - Electronic Discovery Reference Model

Privilege Logs, Null Sets, Search Strings, and Number of Custodians in One Decision

The decision in Cook v. Meta Platforms, Inc., 2024 WL 251942 (N.D. Cal. Jan. 21, 2025), packs a lot into very few pages.  In two instances, where Meta had offered a compromise solution, the court held Meta to that offer....more

McGuireWoods LLP

Court Adopts Variation of Bizarre Privilege Principle

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Several courts have adopted a nonsensical principle that, as one court put it, “[w]hen documents are prepared for dissemination to third parties, neither the document itself, nor preliminary drafts, are entitled to immunity.”...more

Association of Certified E-Discovery...

Understanding the Dominant Purpose Test for Determining Whether Privilege Applies

In complex litigation, understanding when a document is protected by attorney-client privilege can be challenging, especially when privilege issues arise in multidistrict litigation (MDL) like the In re Uber Technologies,...more

EDRM - Electronic Discovery Reference Model

What “Expenses” Can a Non-Party Recover for Complying with a Discovery Subpoena?

In OL Private Counsel, LLC v. Olson, 2024 WL 4839277 (D. Utah Nov. 20, 2024), the court addressed recovery of expenses by non-parties for responding to a subpoena....more

EDRM - Electronic Discovery Reference Model

Court-Ordered Production of a “Destruction/Unavailable” Log

I have never heard of a “destruction/unavailable” log; however, in the comprehensive – indeed, exhaustive – decision of Leprino Foods Co. v. Avani Outpatient Surgical Center, Inc., 2024 WL 4488711 (C.D. Ca. Sep. 30, 2024),...more

EDRM - Electronic Discovery Reference Model

“Attachments to Attorney-Client Communications May Be Withheld as Privileged, Without an Independent Basis for Privilege,” But….

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court held that “attachments to attorney client communications may be withheld as privileged without an independent basis for...more

EDRM - Electronic Discovery Reference Model

When is Failure to Provide a Timely Privilege Log Excusable?

In Melton Properties, LLC v. Ill. Central R. Co., 2024 WL 3015749 at *5 (N.D. Miss. June 14, 2024), the court listed the factors to consider in deciding when the failure to provide a timely privilege log is – or is not – a...more

McGuireWoods LLP

Courts Deal With a Review of Privilege Rulings

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In federal courts, it is nearly impossible to successfully file an interlocutory appeal of a trial court’s order requiring production of privileged documents — despite the obvious “cat out of the bag” nature of such rulings....more

EDRM - Electronic Discovery Reference Model

May’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published May 15, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

Wolf, Greenfield & Sacks, P.C.

Sued: What In-house Counsel Without Litigation Experience Need to Know - Preparing Your Inside Team

3: Preparing Your Inside Team - Preservation, Privilege, Potential Pitfalls -This is the third in a series of articles that explores considerations and suggested actions for in-house counsel who are inexperienced in patent...more

EDRM - Electronic Discovery Reference Model

There’s No Right or Wrong Answer – But There Are Mistakes

In Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. Apr. 3, 2024), the court wrote that “it would be in the parties’ interest to reach a negotiated result. It should not be forgotten that a party could be ‘right,’ but...more

Vinson & Elkins LLP

Review of Attorney-Client Privilege, Work Product Doctrine, and the Crime-Fraud Exception

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A recent privilege dispute in E.D.N.Y. case La Liberte v. Reid provides a prime opportunity to review the law and practical aspects surrounding attorney-client privilege, work product protection, and the crime-fraud exception...more

EDRM - Electronic Discovery Reference Model

What Happens When Parties Fail to Negotiate a Privilege Log in Good Faith?

In Kyle Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. 2024), the court wrote that it “would prefer this case not go to the dark place where attorneys on one side demand that the attorneys on the other side provide...more

Hinshaw & Culbertson - Lawyers for the...

Illinois Appellate Court Rejects the Crime-Fraud Exception in a Defamation Claim

James MacDonald vs. Sally Wagenmaker, et.al., 2024 IL App (1st) 230089 (March 1, 2024) - Brief Summary - An Illinois appellate court reversed a discovery order compelling the defendant law firm to produce privileged...more

Association of Certified E-Discovery...

Privilege Logs and In-Camera Review

[Editor’s Note: This article has been republished with permission. It was originally published November 9, 2023 on the eDiscovery Assistant Blog] This week’s decision comes to us from the case titled 6340 NB LLC v. Cap. One,...more

Thomas Fox - Compliance Evangelist

All Things Investigations: Episode 37 – Privileges in Document Production with Mike Huneke

In this episode of All Things Investigations, host Tom Fox and guest Mike Huneke explore a complex legal case involving Cognizant Technologies and former executives facing criminal charges for alleged bribery. The court’s...more

Farrell Fritz, P.C.

Pitfalls for Corporate Counsel in Business Divorce Disputes

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No corporate lawyer wants to get drawn into a nasty litigation between an entity’s owners. But the reality is that corporate and general counsel often find themselves unwittingly ensnared in business divorce cases. Sometimes...more

McGuireWoods LLP

Are All Government Agencies Part of One “Client” for Privilege Purposes?

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Courts take differing positions on the "client's" identity in the government setting. Among other things, such differing positions might affect the waiver implications of one government agency disclosing its privileged...more

McGuireWoods LLP

Delaware Federal and State Courts Disagree About a Key Privilege Waiver Issue

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Under some arrangements, major shareholders appoint directors to companies those shareholders partially own. Does such a company waive its privilege by disclosing its privileged documents to a designating shareholder's...more

McGuireWoods LLP

In Camera Reviews’ Process and Downside: Part II

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Last week's Privilege Point described courts' various standards for their in camera review of withheld documents. The vast majority recognizes the trial court's discretion, but some courts always conduct an in camera review...more

Faegre Drinker Biddle & Reath LLP

Supreme Court to Resolve Three-Way Circuit Split Involving Attorney-Client Privilege

For the first time in 25 years, the U.S. Supreme Court is considering the scope of the attorney-client privilege in the case In re Grand Jury, No. 21-1397. The Court heard oral arguments earlier this week about when the...more

McGuireWoods LLP

Do Regular Attorney-Client Principles Apply in the Governmental Setting?

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Courts' application of the attorney-client privilege to government lawyers' communications reflects the tension between the public interest in government transparency and the societal benefit of public officials and employees...more

Epstein Becker & Green

Supreme Court to Review Scope of Attorney-Client Privilege for “Dual Purpose” Communications

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The Supreme Court recently granted certiorari in In re Grand Jury to resolve a circuit split regarding what standard governs the application of the attorney-client privilege to dual-purpose communications, that is...more

McGuireWoods LLP

May Litigants Advance Their Case Using Purloined Privileged Documents?

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Given the vulnerability of electronic communications to intrusion, lawyers sometimes obtain and may be tempted to use documents that their clients have inappropriately obtained from an adversary – even privileged documents....more

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