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Work-Product Doctrine

McGuireWoods LLP

Court Handling Case Against Sidley Austin Finds Classic “At Issue” Waiver

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Most privilege and work product waivers involve the intentional or accidental disclosure of protected communications to third parties. But under an “at issue” waiver, a litigant can forfeit both protections without disclosing...more

Cooley LLP

Sixth Circuit Shields Internal Investigation Materials From Discovery

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In a closely watched case, the US Court of Appeals for the Sixth Circuit recently took a significant step to protect the attorney-client privilege over materials produced during internal investigations by companies. On August...more

Freeman Law

A Vessel Without a Port & Loose Lips | The Attorney-Client Privilege

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In the 1993 film The Firm, attorney Mitchell McDeere (played by Tom Cruise) must confront Joey Morolto (played by Paul Sorvino), the head of the Morolto crime family and a top client of Bendini, Lambert & Locke, the law firm...more

Brownstein Hyatt Farber Schreck

Sixth Circuit Opens Path for Broad Privilege Application to Internal Investigations

A recent federal appellate court decision demonstrates one way businesses can use a very limited showing to protect internal investigations from discovery in commercial litigation....more

Womble Bond Dickinson

Sixth Circuit Provides Clarity about Application of Attorney-Client Privilege and Work-Product Doctrine to Internal Investigations

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Business entities facing civil, criminal, or regulatory threats frequently turn to law firms to conduct internal investigations, which can be critical in formulating an appropriate response. A recent ruling from the Southern...more

Woods Rogers

Sixth Circuit Protects Corporate Internal Investigations

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In a notable victory for corporations, the U.S. Court of Appeals for the Sixth Circuit issued a critical ruling in In re: FirstEnergy Corporation that strengthens the protections of the attorney-client privilege and...more

Foley & Lardner LLP

Sixth Circuit Affirms Attorney-Client Privilege and Work-Product Protection over Internal Investigation Materials

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Internal investigations have become a relatively normal part of doing business, but that does not mean the fruits of those investigations are discoverable even if they have a “business purpose.” The U.S. Court of Appeals for...more

Array

This Week in eDiscovery: What to Know About Subject Matter Waiver of Work Product

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of August 3-9. Here’s what’s...more

Array

This Week in eDiscovery: Privilege Decision on Litigation Funding | Meet Array at ILTACON

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of July 27-August 2. Here’s what’s...more

StoneTurn

Safeguarding Privilege Between Counsel and Investigations and Crisis Communications Consultants

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When a corporate crisis hits, attorneys often bring in investigators and PR consultants to uncover facts and manage reputational risk. But without the right structure, those critical communications may not be protected by...more

WilmerHale

Notable Developments In Massachusetts Law: Business Litigation Session Adopts First Circuit Standard For Subject Matter Waiver Of...

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On July 25, 2025, Superior Court Business Litigation Session Judge Debra A. Squires-Lee issued a significant decision regarding the attorney-client privilege and clarifying the contours of the work product doctrine in...more

Cozen O'Connor

Southern District Court of New York Permits Extensive Discovery of Reserve And Reinsurance Information in Bad Faith Litigation

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In Mandarin Oriental, Inc. v. HDI Glob. Ins. Co. et al., Civil Action No. 23 Civ. 4951, 2025 WL 1638071 (S.D.N.Y. June 10, 2025), the District Court of the Southern District of New York followed the modern trend and allowed...more

EDRM - Electronic Discovery Reference Model

Application of Work-Product Doctrine to Materials Prepared Years After Incident

In Hall v. Baltimore Police Dept., 2025 WL 1548560 (D. Md. May 30, 2025)(Austin, J.), the Court considered whether materials created many years after the underlying incident were protected under the work-product doctrine. The...more

Akin Gump Strauss Hauer & Feld LLP

District Court Declines to Order Production of Test Results Referenced in Complaint and Initial Disclosures

The Northern District of Ohio denied a motion to compel the plaintiff to produce test results referenced in its initial disclosures and complaint. The court found that because the “test results are not facts but rather are...more

McGuireWoods LLP

Can Business Adversaries Safely Share Work Product?

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Unlike the fragile attorney-client privilege that can be waived even upon disclosure to family members, the work product doctrine is much more robust. A recurring corporate scenario confirms this important distinction....more

McGuireWoods LLP

No Lawyer Required: Part II

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Last week’s Privilege Point described generally accepted principles under which the attorney-client privilege can protect intra-corporate communications without a lawyer’s involvement. To some lawyers’ surprise, the...more

Seyfarth Shaw LLP

Pay Equity Studies in Focus: Navigating Privilege and Public Disclosure Risks

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A recent decision from the U.S. District Court in Kansas—Spears v. Thermo Fisher Scientific—ruled that a pay equity analysis conducted primarily for business purposes was not protected by attorney-client privilege or the work...more

Jenner & Block

[Ongoing Program] CLE Relay - Session 2 - Protecting Privilege in Times of Crisis - June 6th, 10:00 am - 11:00 am PDT

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This one-hour Ethics CLE program will cover the challenges to attorney-client privilege that may arise during a corporate crisis, including tips to communicate with attorneys and outside consultants, invoking the common...more

Alston & Bird

Wave Goodbye to the Waiver Debate: Court Holds Data Breach Investigation Report Not Work Product from the Start

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Litigants in data breach class actions often fight over whether a data breach investigation report prepared in response to the breach is protected by the work-product doctrine. Common areas of dispute include whether the...more

Venable LLP

To Be or Not to Be...Discoverable: Third-Party Litigation Funders

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Should California courts permit litigants to conduct discovery into litigation funding, namely whether a third party is funding their adversary’s litigation efforts?...more

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

Court Issues a Double-Barreled Rejection of Litigants’ Common Interest Doctrine Claims

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The common interest doctrine can sometimes protect as privileged communications between separately represented clients. But litigants seeking the doctrine’s protection face many hurdles and often fail....more

McGuireWoods LLP

Are Lists of People With Claims or Pertinent Knowledge Work Product Protected?

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Discovery rules and court orders normally require litigants to list people with possible claims or potentially responsive information. But as in many other contexts, the “intensely practical” work product doctrine can apply...more

McGuireWoods LLP

How Does Work Product Protection Apply to Lawyers’ Witness Interview Notes? Two Courts Disagree on the Same Day: Part II

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Last week’s Privilege Point described a court’s review of a lawyer’s conversation with a witness and its conclusion that none of the conversation deserved the heightened opinion work product protection. LaBudde v. Phoenix...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

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