In Aland v. Mead, 327 P.3d 752 (Wyo. 2014) (No. S-13-0119), the Wyoming Supreme Court held that notes and memoranda prepared by non-lawyers are privileged if they reveal the substance of attorney-client communications. Here, a non-lawyer in the governor’s office, Ferrell, prepared two documents that related to communications he had on behalf of the governor’s office with the Wyoming Attorney General’s Office. The first document consisted of notes Ferrell took during a conversation he had with a deputy attorney general, reflecting the attorney’s legal advice. The second document was a memorandum that Ferrell sent to another non-attorney, the Governor’s policy advisor, in which he recounted legal advice Ferrell had received from the deputy attorney general. Plaintiff argued that neither document was privileged because one document consisted of notes of a non-lawyer, and the second document was a communication between two non-lawyers. In rejecting plaintiff’s argument, the court held that, although the documents were not themselves communications with counsel, the documents recounted the substance of communications with counsel, including counsel’s legal advice. Therefore, the documents were privileged.