In Behunin v. Superior Court of Los Angeles County, 9 Cal. App. 5th 833 (Cal. Ct. App. 2017), the court of appeal, as a matter of first impression in California, held that counsel’s communications with a public relations consultant hired by counsel at the client’s direction were not privileged. In this matter, Behunin sued Charles Schwab and his son over an unsuccessful real estate investment deal. Behunin’s lawyer engaged a public relations consultant to create a website containing information linking the Schwabs and their investments in Indonesia to the family of former Indonesian dictator Suharto. The Schwabs brought an action for defamation and sought discovery of communications among Behunin, his lawyers, and the consultant; Behunin objected based on the attorney-client privilege. The trial court overruled the objection, and Behunin filed a petition for a writ of mandate with the appellate court. The appellate court held, as a matter of first impression in the California courts, that although in some circumstances the attorney-client privilege may extend to communications with a public relations consultant, it did not do so in this case because Behunin failed to prove the disclosure of the communications to the consultant “was reasonably necessary for [counsel’s] representation” of Behunin in his lawsuit against the Schwabs. The court found that Behunin had not established that the involvement of the public relations consultant was necessary to facilitate the communications between plaintiff and his counsel, as in the case of a translator or an accountant clarifying communications between an and attorney and client, nor had the consultant improved the comprehension of communications between attorney and client.