In Levy v. Senate of Pennsylvania, 65 A.3d 361 (Pa. Apr. 14, 2013) (No. 44-2012), the Supreme Court of Pennsylvania held that, in specific circumstances, the identity of a client may be privileged. The court also held that while attorney billing records generally are not privileged, the content of those records may be privileged in certain instances. In this matter, pursuant to Pennsylvania’s Right-to-Know Law, a journalist submitted a request to the Pennsylvania Senate seeking documents relating to the legal representation of Senate Democratic Caucus employees. The Senate produced the documents, including billing records and engagement letters. The documents were heavily redacted, however, including specific descriptions of legal work provided that appeared in billing records, and in some instances the names of the clients. With respect to client identities, the court held that, while not generally privileged, client identities should be protected in rare circumstances in which disclosure of the identity alone would reveal information otherwise protected by the attorney-client privilege. This rule may apply in either civil or criminal actions. Here, the court held that the identities of the clients did not need to be withheld because the content of the documents was so heavily redacted that disclosure would not reveal otherwise privileged information. With respect to the content of the billing records, the court held a party may redact those portions of the records that would result in disclosure of otherwise privileged information, such as: descriptions of legal services that address the client’s motive for seeking counsel, legal advice, strategy, or other confidential communications. The court approved of the trial court’s careful line-by-line in camera analysis of the redactions here.