DOS and DON’TS of a 30(b)(6) Witness Deposition, Part Five
eDiscovery Daily
OCTOBER 1, 2019
But other privileges may be at risk as well, including: Common Interest Privilege. The risk is that work product and other privileges overlapping as case facts become mixed with trial counsel’s mental processes and legal strategies. 8:09-cv-455-T-23TBM (M.D. Protection of privileges. Deliberative Process Privilege. McCabe, No.
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