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Litigation Strategies Discovery Attorney-Client Privilege

Array

This Week in eDiscovery: A Self-Collection Warning | ‘Sufficient to Show’ Requests

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of June 29-July 5. Here’s what’s...more

Kerr Russell

Five Tips for Preparing to Testify at a Deposition

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Preparing for a deposition can be challenging whether it is a person’s first or hundredth time testifying under oath. Being questioned frequently causes anxiety. But the experience does not have to be so daunting with...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Two Recent CHRT Rulings Rein in Over-Broad Human Rights Litigation - What Employers Should Know

Employers that defend against human rights complaints often find themselves grappling with pleadings and submissions that wander well beyond the events the complainant experienced. ...more

DarrowEverett LLP

Before You Hit ‘Record’: Legal Risks In Using AI Notetaking Tools

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You may have asked a team member or associate to jot down notes during a Zoom call, only to find that they struggled to capture every key point while also actively participating in the discussion. Or perhaps you aimed to...more

Seyfarth Shaw LLP

Pay Equity Studies in Focus: Navigating Privilege and Public Disclosure Risks

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A recent decision from the U.S. District Court in Kansas—Spears v. Thermo Fisher Scientific—ruled that a pay equity analysis conducted primarily for business purposes was not protected by attorney-client privilege or the work...more

WilmerHale

Preparing for Securities Litigation: Strategic Coordination with Crisis Response

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When a public company confronts a crisis, whether stemming from regulatory scrutiny, operational setbacks, or some other unfortunate development, securities litigation exposure materializes rapidly. ...more

Nextpoint, Inc.

Key Discovery Points: Navigating Clawbacks When In-House Counsel Are Included

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In this Key Discovery Points video, Brett Burney of Nextpoint and Doug Austin of eDiscovery Today break down a key antitrust ruling in De Coster v. Amazon.com, where a judge ordered 54 of 85 documents reviewed in camera to be...more

Array

This Week in eDiscovery: Be Careful What Your ESI Protocol Says

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of May 11-17. Here’s what’s...more

McGuireWoods LLP

Can One Jointly Represented Client Waive the Groupꞌs Privilege?

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Lawyers frequently represent multiple clients on the same matter. Absent some contractual arrangements to the contrary, those lawyers must share all confidential information with all the jointly represented clients and, of...more

Baker Donelson

Privilege Under Fire: Protecting Forensic Reports in the Wake of a Data Breach

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In the chaos following a cyberattack, forensic reports are often pulled together under intense pressure and can assist companies in responding to and remediating the incident. However, if you're not careful, these reports...more

TransPerfect Legal

Search Term Translation for eDiscovery: The Art & Science of Getting the ‘Technical Translation’ Right

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When it comes to eDiscovery, term translation isn't just about converting words from one language into another. It's a highly specialized process that requires a nuanced understanding of both linguistics and technical search...more

A&O Shearman

Medibank class action: navigating the legal privilege maze

A&O Shearman on

Concerns about claims of legal professional privilege over third-party investigation reports produced in the course of responding to cyberattacks, and the extent to which such reports can be shielded from disclosure in legal...more

McGuireWoods LLP

How Does Work Product Protection Apply to Lawyers’ Witness Interview Notes? Two Courts Disagree on the Same Day: Part II

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Last week’s Privilege Point described a court’s review of a lawyer’s conversation with a witness and its conclusion that none of the conversation deserved the heightened opinion work product protection. LaBudde v. Phoenix...more

EDRM - Electronic Discovery Reference Model

Another Approach to Drafting and Discovery of Litigation Hold Notices

By definition, a litigation hold notice is a communication from an attorney to a client regarding the duty to preserve potentially responsive information. In Homeland Ins. Co. of Del. v. Independent Health Ass’n., Inc., 2025...more

Husch Blackwell LLP

Why a Sorority’s Interview Notes Didn’t Stay Private: Lessons in Legal Privilege

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Not everything stamped “privileged” is safe from prying eyes. The Pennsylvania Superior Court recently ruled that interview notes compiled by a sorority’s leadership after a tragic incident were not shielded by...more

McGuireWoods LLP

Another Decision Spawned by Ethical Scandal Highlights Wisdom of Considering All Evidentiary Protections

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In the aftermath of the soap opera-like ethical scandal over an undisclosed romantic relationship between a Jackson Walker partner and a Texas bankruptcy judge, an Oregon federal court dealt with discovery of a renowned...more

EDRM - Electronic Discovery Reference Model

Tailor FRE 502(d) Orders to the Case

Having taught Federal Rule of Evidence 502 (FRE 502) in my law classes for over a decade, I felt I had a firm grasp of its nuances. Yet recent litigation where I serve as Special Master prompted me to revisit the rule with...more

Minerva26

Privilege Log, Privilege Log — It’s All About the Description

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A privilege log is the absolute bane of an attorney’s existence. I don’t mean it isn’t important and a critical component of discovery, but the level of planning, analysis and detail required to complete such a log is...more

Kilpatrick

Blurred Lines: Personal Devices, Proportionality, and Piercing the Work Product Privilege

Kilpatrick on

In a fairly short opinion and order, the district court in Weston v. DocuSign, Inc. analyzed whether the parties were entitled to the production of text messages from former employees’ personal devices and potential piercing...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

Robins Kaplan LLP

Unintended Consequences: Don’t Forget the Litigation Risks When Getting a Deal Done

Robins Kaplan LLP on

Transactional attorneys play a key strategic role in drafting essential documents, such as corporate formations and contracts, on behalf of corporate clients. With a client’s current needs at the forefront—often accompanied...more

Jackson Lewis P.C.

To Be (Discoverable), or Not to Be: Notetaking During an Attorney’s Internal Investigation

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Introduction- Picture this: you are on-site at a new client’s headquarters for a weeklong hostile work environment investigation into several internal complaints made against the CEO and CFO. This is the first engagement...more

Jenner & Block

Privilege Newsletter: Fitting Consultants Within the Attorney-Client Privilege and Work Product Protection – Cyber Breach...

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Cyber attacks are increasingly frequent and virulent. An intruder may lurk in a company’s computer system for years, or an attack may be sudden and catastrophic. Millions of people’s personal information and companies’...more

Nextpoint, Inc.

Ediscovery Checklist: How to Win the Rule 26(f) Meet and Confer

Nextpoint, Inc. on

Preparing for the Meet and Confer - Proper preparation and documentation during the Rule 26(f) meet and confer process will greatly improve efficiency in the ediscovery phase of your litigation....more

Searcy Denney Scarola Barnhart & Shipley

What is the Status of Discovery of an Expert Witness Relationship?

In Wirley v. Central Florida Young Men’s Christian Association, 228 So.3rd 18 (Florida, 2017), the Supreme Court ruled disclosure of a financial relationship between a party, a plaintiff’s attorney and an expert, is no longer...more

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