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Privilege

Educate Your Clients About Two Basic Privilege Misperceptions

Attorney-client privilege protection depends on a communication’s content — which must be primarily motivated by the client’s request for legal advice.

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Privilege

Courts Disagree About Privilege Log Requirements: Part II

Last week’s Privilege Point described one court’s incredible requirement that litigants identify everyone who learned of a withheld document’s content — even if they were not shown as a recipient.

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Privilege

Courts Disagree About Privilege Log Requirements: Part I

All or nearly all courts require litigants to log documents withheld on privilege or work product grounds (with an exception discussed next week). But they disagree about what the log should include — with some courts taking an unrealistically expansive view.

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Privilege

What’s the Deal With “Intangible” Work Product? Part III

The last two Privilege Points (Part I and Part II) explained that the 1947 U.S. Supreme Court decision in Hickman v. Taylor, 329 U.S. 495 (1947), created a common law protection for litigation-related tangible and intangible things.

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Privilege

Does Disclosure During Settlement Negotiations Waive Work Product Protection?

For obvious reasons, the law encourages settlements. During settlement negotiations, participants may be tempted to disclose work product-protected documents or intangible communications.

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Privilege

What’s the Deal With “Intangible” Work Product? Part II

Last week’s Privilege Point explained that nearly every court extends work product protection beyond the “documents and tangible things” specified in Fed. R. Civ. P. 26(b)(3) and understandably mentioned in a recent Southern District of New York decision.

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Privilege

What’s the Deal With “Intangible” Work Product? Part I

The “work product” doctrine provides an entirely separate protection from the attorney-client privilege.

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