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Privileged Communication Work-Product Doctrine

Lowndes

Florida Law Update: Slack Messages May Be Privileged Communication

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Florida’s Sixth District Court of Appeal (6th DCA), which considers appeals from trial courts in an area running from Orange County down to Collier County, recently confirmed that discovery privileges apply to communications...more

McGuireWoods LLP

Assessing Privilege Protection for Training Materials and Presentations: Part I

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Lawyers and non-lawyers frequently train their corporate colleagues. Determining any applicable attorney-client privilege or work product protections can implicate a number of variables....more

McGuireWoods LLP

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

McGuireWoods LLP

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

McGuireWoods LLP

Non-Lawyer Corporate Employees Can Claim Privilege Protection for Investigation-Related Communications

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Outside and in-house lawyers may of course normally claim privilege protection for their investigation-related communications, as long as they were primarily motivated by the need for legal advice. Depending on the...more

McGuireWoods LLP

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

Pietragallo Gordon Alfano Bosick & Raspanti,...

Preserving Privilege in Internal Investigations

One thing leaders of organizations routinely recognize is that “you never know what tomorrow will bring.” Another common slogan is “life happens.” If “life” happens to bring the organization a situation that could expose the...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

Seyfarth Shaw LLP

Key Developments In Equal Pay Litigation: Maintaining Privilege Over Pay Equity Audits And Investigations

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Seyfarth Synopsis: In its seminal decision, Bostock v. Clayton County, Georgia, the Supreme Court held that discrimination on the basis of sexual orientation or gender identity is tantamount to discrimination on the basis of...more

Kilpatrick

The Attorney-Client Privilege: The Corporate Communication Conundrum – Part II

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As anyone faced with discovery requests knows, one of the most important parts of producing documents is determining what documents are subject to attorney-client privilege or work product doctrine and must therefore be...more

McGuireWoods LLP

Do Not Forget the Consequences of Judges’ Role in Assessing Privilege Protection

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In both the federal and state judicial systems, judges assess privilege and work product protection claims — sometimes coordinating with judges at other levels. But there is a lurking unspoken risk that some lawyers may...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

McGuireWoods LLP

What’s the Deal With “Intangible” Work Product? Part II

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Last week’s Privilege Point explained that nearly every court extends work product protection beyond the “documents and tangible things” specified in Fed. R. Civ. P. 26(b)(3) and understandably mentioned in a recent Southern...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

Smith Anderson

N.C. Business Court Strengthens a Company’s Ability to Assert the Attorney-Client Privilege in Disputes with Officers and...

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With its origins in the 16th century, the attorney-client privilege is one of the oldest doctrines in our common law tradition. Even so, new issues do arise, like in the North Carolina Business Court case Hosie v. 8 Rivers...more

McGuireWoods LLP

What Can Corporations Safely Share With Their Auditors?

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Corporations risk waiving their fragile privilege protection by sharing protected communications with even the friendliest outsiders — such as their retained public relations consultants, etc. They must disclose some...more

McGuireWoods LLP

Can Any Data Breach Investigation Report Deserve Protection? Part II

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Last week’s Privilege Point described a data breach victim’s latest losing effort to claim privilege protection for its consultant’s investigation report. Leonard v. McMenamins Inc., Case No. C22-0094-KKE, 2023 U.S. Dist....more

McGuireWoods LLP

Sending an Adversary a Draft Complaint Does Not Waive Privilege or Work Product Protection

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Would-be litigants sometimes send a draft complaint to the would-be adversary — either to deter their bothersome conduct or to spur settlement talks. That scenario frequently raises defamation issues — with states taking...more

McGuireWoods LLP

Rare Opinion Extends Privilege Protection to Implicit Request for Legal Advice

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Overworked judges assessing possible privilege protection for the increasing volume of often-cryptic emails withheld from production understandably look for a client’s explicit request for legal advice from a lawyer....more

Wilson Sonsini Goodrich & Rosati

Swords and Shields: Forging Strong Attorney-Client Relationships

Host Mary O'Brien is joined by Wilson Sonsini corporate partner Craig Sherman as she interviews Bungie General Counsel Don McGowan to discuss forging strong attorney-client relationships. Conversation Highlights: Don...more

McGuireWoods LLP

Two Federal Courts Assess a Prospective Client’s Privilege Protection on the Same Day

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Communications between a lawyer and a prospective client can involve ethics (confidentiality and conflicts) issues, as well as privilege protection issues. Not surprisingly, the availability of privilege protection depends on...more

Jenner & Block

Protecting Confidential Legal Information: A Handbook Analyzing Issues under the Attorney-Client Privilege and the Work Product...

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I. THE ATTORNEY-CLIENT PRIVILEGE - Historically, the attorney-client privilege developed upon two assumptions: (1) good legal assistance requires full disclosure of a client’s legal problems; and (2) a client will only ...more

DarrowEverett LLP

Court Rulings Demonstrate That Privilege Is Not Always a Right

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Earlier this year, following oral argument and 16 amicus submissions, the Supreme Court dismissed as improvidently granted (“DIG”) a writ of certiorari on the issue of whether communications involving both legal and non-legal...more

McGuireWoods LLP

Federal and State Courts Issue Helpful Investigation-Related Decisions: Part II

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Last week’s Privilege Point described a federal court case holding that explicit reliance on a consultant's investigation waived fact work product protection related to the investigation — but not opinion work product...more

McGuireWoods LLP

State Courts Offer Some Hope for Adverse Privilege Rulings' Interlocutory Appeals

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Federal courts have eliminated nearly any chance for unsuccessful trial court litigants to immediately appeal adverse privilege or work product rulings – inexplicably rejecting the obvious "cat out of the bag" nature of such...more

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