Supreme Court of New York, Appellate Division, First Department, December 2, 2021
We previously reported on a dispute concerning the discoverability of a defendant’s redacted, as well as unredacted memorandum from the defendant’s in-house counsel to its president. In 2016, a New York trial court held that privilege was waived by the defendant as to both the redacted and unredacted memo. In 2017, the New York Appellate Division, First Department, modified the trial court’s decision. They agreed that privilege was waived as to redacted memo, …
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