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District of Columbia Circuit holds that providing attorney work product to independent auditors does not per se waive the protection of the work product doctrine

  • Sheppard Mullin Richter & Hampton LLP
  • -
  • USA
  • -
  • July 23 2010

In United States v Deloitte LLP, No 09-5171, 2010 WL 2572965 (DC Cir Jun 29, 2010), the United States Court of Appeals for the District of Columbia Circuit held, among other things, that the provision of documents containing attorney work product to a company's independent auditor does not waive the protection of the work product doctrine