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Courts Use Rule Language and Common Sense to Expand Work Product Protection: Part I

Unlike the common law-dominated attorney-client privilege which developed organically in each state, work product protection comes from court rules. One might think that this would simplify courts' application of that...more

Does a Client Risk Privilege Protection by Bringing Her Mother to a Lawyer Meeting?

Because it is absolute and can hide important facts from easy discovery, the attorney-client privilege is hard to create, narrow, and fragile. Among other things, even friendly third parties' presence can abort privilege...more

The Trouble with Drafts: Part I

Because attorney-client privilege protection depends on confidentiality, the privilege evaporates once clients determine to disclose privileged communications – even before the disclosure occurs. For example, the final...more

Can the Privilege Protect Communications in a Public Place?

If clients and their lawyers engage in otherwise privileged communications in the presence of third parties, the privilege rarely if ever protects the communications. But what if the communications occur in a public place...more

Two Decisions Issued the Same Day Highlight Choice of Laws Issues: Part II

Last week's Privilege Point described a Maine case applying the narrow pre-Upjohn "control group" standard for corporate communications. Harris Mgmt., Inc. v. Coulombe, 2016 ME 166, ---A.3d---. Illinois is by far the largest...more

Court Analyzes Possible Privilege Protection for Communications with Public Relations Consultants

Corporations and their lawyers frequently work with public relations consultants when facing ongoing or anticipated litigation. In the work product context, courts agree that disclosing preexisting work product to such...more

Does Sharing Work Product with the Government Always Waive that Protection?

For decades, companies trying to cooperate with the government have hoped for a change in the general rule that disclosing privileged communications and/or work product to the government waives those protections. In nearly...more

Court Concludes That Access to Privileged Document by Employees Without a "Need to Know" Does Not Destroy Privilege Protection

Many courts hold that corporations might waive their privilege protection through purely internal circulation of privileged communications — beyond those employees with a "need to know." ...more

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