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German Company Seeking U.S. Discovery Gets Good News, Bad News and Some Good News: Part II

Last week’s Privilege Point described a Southern District of New York magistrate judge’s application of the “touch base” privilege test to a German company’s application to conduct discovery of a U.S. private equity company’s...more

Litigants Confuse a Common-Interest Agreement With Joint Representation

The common-interest doctrine sometimes protects as privileged communications between separately represented clients sharing an identical legal interest in ongoing or anticipated litigation. It differs dramatically from a...more

Court Analyzes the “Testamentary Exception” — With a Twist

Under the aptly named “testamentary exception,” a beneficiary taking under a will can sometimes access communications between the testator and the testator’s lawyer. This exception rests on the understandable concept that the...more

How Does a Rule 502(d) Order Work?

Under Fed. R. Evid 502(d), a federal court can assure that an inadvertent disclosure of privileged documents in the case before it will not allow litigants in subsequent cases to argue that such disclosure triggered a...more

California Federal Court Addresses Discovery About Discovery

Aggressive litigation adversaries sometimes try to make a discovery sideshow into the main event. A party’s search for responsive documents occasionally triggers such an effort....more

Why Do Privilege Disputes Never Seem to Focus on Lawyers' Ethics Confidentiality Duty?

Every lawyer knows the incredible scope and strength of their ethics confidentiality duty. More than any other profession, lawyers must maintain the absolute secrecy of nearly all information relating to their clients. But...more

Should Litigants Count on Private Non-Waiver Agreements?

When negotiating their respective privilege claims, litigants sometimes face the temptation to agree among themselves that producing some arguably protected withheld documents will not trigger a subject matter waiver...more

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