In Scott v. Chipotle Mexican Grill, Inc.,No. 12-CV-08333 (S.D.N.Y. Mar. 27, 2015), the district court held that disclosing legal advice to corporate employees who can act on and implement the advice does not waive the privilege, even when the advice is being discussed among non-legal personnel.  Here, plaintiff argued that withheld emails that did not include a lawyer among the authors or recipients should be reviewed in camera because they may not be legal in nature.  After in camera review, the court found that the email communications, although among non-legal personnel, referred or discussed legal advice received by the company and were related to implementing that advice.  The court held that, “to the extent that it is correct that all recipients were able to act upon or implement the information or advice they received . . . the e-mails and the attachments are privileged.  To hold otherwise would disable corporations from implementing legal advice, exactly what Upjohn seeks to avoid.”