Depositions and Privileged Communication

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Depositions

Privileged Communication

Privilege Waiver by: Disclosure to Therapist; and, in Rule 30(b)(6) Deposition Preparation

E-Discovery LLC

SEPTEMBER 18, 2024

Second , where a Rule 30(b)(6) deponent reviewed an allegedly privileged document in deposition preparation in order to refresh her memory, the privilege, if any, was waived. WAIVER OF A-C PRIVILEGE BY DISCLOSURE IN THERAPY Plaintiff produced redacted records of notes prepared by her therapist, a licensed social worker.

Depositions

Depositions Privileged Communication Witnesses Discovery

Good Help: Non-lawyer Assistants—Human and Virtual

WA Bar News

JULY 10, 2024

Although the court denied the motion, it was only after depositions of the personnel involved and an evidentiary hearing involving outside counsel. The paralegal later viewed 972 privileged emails and moved them into the firm’s case database. Comment 11 was later added to Washington RPC 1.10 citing Daines , cross-referencing RPC 5.3,

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Privilege Waiver by: Disclosure to Therapist; and, in Rule 30(b)(6) Deposition Preparation

Good Help: Non-lawyer Assistants—Human and Virtual

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