On June 14th, the Federal District Court for Kansas addressed an issue of first impression in that District, whether a law firm may independently claim work product protection when the client has waived it. It holds that the law firm cannot and, moreover, that the firm's "entire file", not just the "end product", must be produced. That outcome was particularly applicable where, as here, the defendant's interests and those of the firms were not aligned. The defendant explicitly asserted reliance on counsel's advice in opposing the penalties sought by the SEC. Additionally, the Court adopted the magistrate's finding that the law firm had waived any independent right to assert work product protection it may have had respecting disclosure of documents created for law office use and review. SEC v. McNaul.