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Privileged Documents Privileged Communication

McGuireWoods LLP

Clients Lose Some, Win Some – Two Courts Assess the Common Interest Doctrine on Same Day: Part I

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The common interest doctrine can sometimes protect as privileged communications between separately represented clients who share an identical legal interest in litigation, or in anticipation of litigation. But satisfying this...more

McGuireWoods LLP

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

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

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

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...

[Webinar] How to Enhance Corporate Investigations on Apple Devices - August 22nd, 10:00 am PDT

Despite the dominance of Windows computers in corporate environments, an increasing number of companies are now integrating Apple Mac computers into their networks. Alongside this shift, the rise of BYOD (Bring Your Own...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

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

McGuireWoods LLP

Court Takes Expansive View of an Implied Waiver: Part II

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Last week’s Privilege Point described an opinion requiring a corporate party’s witness to disclose communications with his Latham & Watkins lawyers, because he confirmed with that firm his own “commercial understanding” about...more

Blake, Cassels & Graydon LLP

Alberta : Précisions sur la portée des demandes d’organismes de réglementation et la renonciation au secret professionnel

Dans la décision CNOOC Petroleum North America ULC v. ITP SA (la « décision »), la Cour d’appel de l’Alberta (« CAA ») a passé en revue les principes relatifs au privilège relatif au litige et à la renonciation à ce privilège...more

Bennett Jones LLP

Protecting Privilege on Construction Projects

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Construction projects are often complex and involve many different parties and moving parts. This often necessitates a continued investigation of facts and assessment of legal rights and obligations to ensure that the owner...more

Blake, Cassels & Graydon LLP

Comply with Demands by Regulators and “Waive” Goodbye to Privilege? New Alberta Guidance on Scope of Regulatory Requests

In CNOOC Petroleum North America ULC v. ITP SA (Decision), the Alberta Court of Appeal (ABCA) revisited the principles of privilege and waiver of privilege in the context of two reports that arose from an internal...more

McGuireWoods LLP

Where Should Lawyers Look for the Applicable Attorney-Client Privilege?

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The attorney-client privilege originated in Roman law, and flourished under what John Adams labeled "that most excellent monument of human art, the common of law of England." But in America, some states articulate their key...more

Carlton Fields

You Keep Using That Word, I Do Not Think It Means What You Think It Means: Accountant-Client “Privileged” Communications May Not...

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In Florida, the legislature deemed open dialogue between an accountant and a client so important that, in 1978, it adopted a privilege nonexistent in the common or law: the accountant-client privilege....more

Holland & Knight LLP

Providers Negotiating with Doctors Who Have Restrictive Covenants Beware

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Providers negotiating with doctors and other medical professionals who are bound by enforceable restrictive covenants is tricky business. By virtue of his/her/their position, these physicians may owe fiduciary duties to the...more

Bennett Jones LLP

Privilege is Sacrosanct: Ontario Court of Appeal Affirms High Threshold for Abrogation of Privilege

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Legislation must show a clear, explicit and unequivocal intention to abrogate privilege before a party is required to disclose privileged information, the Ontario Court of Appeal reiterated in its recent decision of Ontario...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

Southern District of California Applies the Sporck Doctrine

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In 1985, the Third Circuit protected as opinion work product a lawyer's "selection and compilation of [intrinsically unprotected] documents . . . in preparation for pretrial discovery." Sporck v. Peil, 759 F.2d 312, 316 (3d...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

McGuireWoods LLP

Court Addresses Privilege Protection for Litigation Holds

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Companies in or anticipating litigation normally impose litigation holds. If litigation ensues, does the attorney-client privilege or the work product doctrine protect the content of such a hold or the fact of its imposition?...more

Lighthouse

Challenging 3 Myths About Document Review During Second Requests

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Legal teams approaching a Hart-Scott-Rodino (HSR) Second Request may hold false assumptions about what is and isn’t possible with document review. Often these appear as necessary evils—compromises in efficiency and precision...more

Blake, Cassels & Graydon LLP

Is Privilege Waived When Cooperating with a Police Investigation?

As Justice Tyndale once stated in a decision rendered by the Quebec Court of Appeal (QCA), "It is common sense that a secret once revealed is a secret no longer." This adage has since been widely used in support of 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

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