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Courts Address Work Product Issues: Part II

Last week's Privilege Point addressed litigants' need to identify the exact moment when they first anticipated litigation. Another work product issue involves the degree of protection afforded opinion work product....more

Courts Address Work Product Issues: Part I

Because work product protection applies only when the creator is in or reasonably anticipates litigation, a litigant asserting that protection must know exactly when that occurred. In other words, as of one moment the...more

Delaware Federal Court Cleverly Finesses Frequently Arising Privilege Issue

Nearly every court requires that litigants analyze possible privilege and work product protection for each attachment included in a withheld email or other document. This understandable approach raises an obvious question...more

Court Issues a Favorable Privilege Decision About an Investigation Report Resulting in an Employee's Firing

Courts frequently face a common scenario: an in-house lawyer investigates alleged employee misconduct, and prepares a report that the company relies on in firing the employee. Do such reports deserve privilege protection, and...more

Beach Boys Author of "I Get Around" Sued by Plaintiffs Whose Lawyer Moves Around

Lawyers who practice law "systematically and continuously" or even temporarily in states where they are not licensed confront unauthorized practice of law and multijurisdictional statutes and rules. Does attorney-client...more

S.D.N.Y. Deals With Spouses and Law Firm Emails: Part I

Most states have adopted some variation of what is called the "spousal privilege" or "marital privilege." Those usually appear in statutes or rules, and dramatically vary from state to state. For obvious reasons, spouses'...more

Bad News and Good News About Communicating With Outside Auditors

One key distinction between attorney-client privilege protection and work product doctrine protection is their fragility. Disclosure to non-adverse third parties normally waives the former, but not the latter. In Breuder...more

Lawyers Beware: Seeking Hard-Copy Printouts of Privileged Emails Can Forfeit the Privilege

Many of us (especially the older generation) like to deal with hard-copy printouts of electronic communications. But inattention to the printout process can have disastrous results....more

Eighth Circuit and S.D.N.Y. Opinions Highlight Common-Sense Strategy to Maximize Privilege Protection

While lawyers should familiarize themselves with the sometimes counter-intuitive and nuanced privilege law, they should never lose sight of the nitty-gritty of courts' application of that law. The attorney-client privilege...more

Courts Differ on the Meaning of the Work Product Rule's "Anticipation" and "Litigation" Elements: Part II

Last week's Privilege Point addressed courts' differing interpretations of the work product rule's "anticipation" element. Fed. R. Civ. P. (26)(b)(3)'s and parallel state rules' "litigation" element also requires courts'...more

Courts Differ on the Meaning of the Work Product Rule’s "Anticipation" and "Litigation" Elements: Part I

Fed. R. Civ. P. 26(b)(3)'s and parallel state work product rules apply to documents and tangible things prepared "in anticipation of litigation or for trial." But the Rule does not specify the degree of required...more

What Is the Garner Doctrine, and Why Is It Dangerous?

Under what is called the "fiduciary exception," a fiduciary's beneficiary sometimes may access otherwise privileged communications between the fiduciary and its lawyer – based on the law's artificial identification of the...more

The Privilege Always Protects Communications Among Jointly Represented Corporate Affiliates, Right?

Corporate parents' in-house lawyers' joint representations of the parent and its wholly-owned subsidiaries should cinch their communications' attorney-client privilege protection. Additional grounds for such privilege...more

Adversaries on Some Litigation Issues Might Share a "Common Interest" on Other Issues

The unpredictable and frequently rejected common interest doctrine can sometimes avoid what would otherwise be a waiver when separately represented litigants share privileged communications or documents. Many clients and even...more

Court Issues Strange Intangible Work Product Decision

Although the federal work product rule and parallel state work product rules extend only to "documents and tangible things," most courts also protect intangible work product such as oral communications – at least to the...more

Having a Big Law Firm Hire a Public Relations Consultant Does Not Assure Privilege or Work Product Protection

Just as some clients think that copying a lawyer cinches privilege protection, even sophisticated clients relying on well-known law firms might erroneously believe that having those law firms hire a public relations...more

Be Sure to Check the Choice of Law Before Analyzing "At Issue" Waivers

The unpredictable "at issue" waiver doctrine can strip away privilege protection without any disclosure of, or explicit reliance on, privileged communications. But state courts and even federal courts take widely varying...more

Actor Justin Theroux's Feud With Neighbors Generates Another Weird Privilege Decision

In December 2020, a New York court noted that A-list actor Justin Theroux and his downstairs neighbors "do not get along, to put it mildly." Theroux v. Resnicow, 2020 N.Y. Slip Op. 51489(U), at *2 (N.Y. Sup. Ct. Dec. 16,...more

Two Moms, Two Cases and Two Different Results: Part II

Last week's Privilege Point described a court's curt rejection of attorney-client privilege protection for a plaintiff's communications with her mom – and noted the court's surprising failure to address an obvious work...more

Two Moms, Two Cases and Two Different Results: Part I

Somewhat counter-intuitively, attorney client privilege protection is so fragile that even a family member often falls outside privilege protection (unless that family member was necessary to facilitate communications between...more

Paralegal's Deposition Testimony Dooms a Work Product Claim

An employer's post-accident investigation deserves work product protection only if it was primarily motivated by anticipated litigation. Thus, such investigations normally do not deserve work product protection if: (1) they...more

The Eureka Doctrine – At the Intersection of Conflicts and Privilege

Not surprisingly, joint clients do not waive their privilege protection when they communicate with their joint lawyer or (in some situations) with each other. But what if a lawyer improperly represents joint clients whose...more

Courts Deal With "Dual-Hat" Experts: Part II

Last week's Privilege Point addressed a court's careful sorting out of discovery issues implicated when a non-testifying consulting expert created documents arguably related to his later role as a testifying expert. About two...more

8/12/2021  /  Expert Testimony , Testimony , Witnesses

Courts Deal With "Dual-Hat" Experts: Part I

Fed. R. Civ. P. 26(a)(2)(B)(ii) governs testifying experts' duty to produce "the facts or data considered by the witness in forming" his or her opinion. Fed. R. Civ. P. 26(b)(4)(D) governs dramatically different...more

"At Issue" Waivers Implicate Subtle Distinctions

The frighteningly unpredictable "at issue" waiver doctrine can strip away attorney-client privilege protection when the client seeks some legal advantage by putting "at issue" its knowledge, ignorance, conduct, etc. This type...more

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