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Privileged Communication Discovery

EDRM - Electronic Discovery Reference Model

Discovery Rulings in Abrego-Garcia v. Noem Deportation Case

In Abrego-Garcia v. Noem, __ F.R.D. ___, 2025 WL 1166402 (D. Md. Apr. 22, 2025)(Xinis, J.), plaintiffs notified the Court of “seemingly intractable discovery disputes….”  The case is before the District Court after the United...more

Esquire Deposition Solutions, LLC

What to Do After Asserting a Deposition Objection

The rule seems simple enough: Attorneys defending a witness during a deposition may instruct the witness not to answer questions only for the purpose of protecting privileged information. And yet, if the number of trial court...more

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Court Confirms Basic Privilege Principles in Giving Princeton a Win

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Because litigants frequently take an aggressive approach when withholding documents on privilege grounds, courts’ in camera reviews often result in a loss for them. But sometimes courts agree with a litigant’s privilege...more

HaystackID

[Webinar] Discovering Data Quickly in High-Stakes White-Collar Investigations - March 12th, 11:00 am - 12:00 pm CDT

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White-collar crimes present investigators with intricate challenges that require precision, expertise, and advanced technology. In today’s high-profile investigations, the stakes couldn’t be higher, with reputations,...more

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

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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

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

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

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When Can a Litigant Overcome the Adversary’s Fact Work Product Protection?

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Unlike the absolute attorney-client privilege (and the absolute or nearly absolute opinion work product doctrine protection), a litigant can overcome the adversary’s fact work product protection if it “shows that it has...more

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Litigation Reserve Estimates: Doctrinal Good News, But Practical Impediments

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Companies facing ongoing or threatened litigation must sometimes estimate their likely or possible financial exposure — for internal purposes, reporting to auditors or other reasons. Depending on the circumstances, one would...more

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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

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Can Advertising Agencies Ever Be Within Privilege Protection?

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Numerous Privilege Points have described cases concluding that advertising agencies are outside privilege protection but inside work product protection (although they normally cannot themselves create protected work product)....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

TransPerfect Legal

It’s Our Privilege to Meet You!

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Over the past year, TransPerfect Legal, in collaboration with Fieldfisher LLP, has hosted three GC roundtables, where in-house legal teams discussed the complexities of managing privilege in today’s decentralised data...more

EDRM - Electronic Discovery Reference Model

Is Marking Documents as “Work Product” an Admission that the Duty to Preserve is Triggered?

In Stuart v. County of Riverside, 2024 WL 3086634, at *3 (C.D. Cal. Jun. 14, 2024), the District Court found a relationship between work product designations and triggering of the common-law duty to preserve....more

McGuireWoods LLP

Two Important Courts in Two Days Highlight the Shrinking Risk of Subject Matter Waivers: Part II

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Last week’s Privilege Point noted the Southern District of New York’s privilege expert’s opinion confirming the modern view that an extrajudicial disclosure of a privileged communication normally does not trigger a subject...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

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Two August Decisions Assess Privilege Protection for Employee-to-Employee Communications

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Corporate litigants’ privilege logs often trigger privilege disputes about internal corporate communications not involving a lawyer — because the log does not mention a lawyers’ participation. But there are at least two...more

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Courts’ “Intensely Practical” Approach to Surveillance Videos

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In contrast to the somewhat abstract doctrine-driven attorney-client privilege, courts have described the work product doctrine as “intensely practical.” Their treatment of defendants’ surveillance videotape of personal...more

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The Surprising Danger of Including a Spouse on Email Communications

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Most lawyers know that state statutes or common law doctrines often protect communications between spouses – although there is wide variation in such approaches. But there is a lurking danger that all of us should keep in...more

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Courts Thankfully Back Away From a Broad “At Issue” Waiver Approach

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Starting about 50 years ago in the case of Hearn v. Rhay, 68 F.R.D. 574 (E.D. Wash. 1975), some courts recognized a broad “at issue” waiver that could strip away privilege without the holder’s disclosure of or even reference...more

EDRM - Electronic Discovery Reference Model

eDiscovery Review in Transition: Manual Review, TAR, and the Role of AI

ComplexDiscovery’s Editor’s Note: This article is essential for cybersecurity, information governance, and eDiscovery professionals navigating the complexities of legal document review. With the rapid advancements in AI...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

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Two S.D.N.Y. Cases Decided the Same Day Provide the Same Key Privilege Guidance: Part I

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Many if not most clients and even some ill-informed lawyers think they can “make” something privileged through some logistical step — such as marking it as “privileged,” copying a lawyer, inviting a lawyer to a meeting, etc....more

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