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Banks v. Office of Senate Sergeant-At-Arms

United States District Court, D. Columbia
May 9, 2005
228 F.R.D. 24 (D.D.C. 2005)

Summary

finding that documents which did not on their face contain requests for legal advice were nevertheless protected because they were compilations of facts for use by counsel in providing legal advice

Summary of this case from Fed. Trade Comm'n v. Boehringer Ingelheim Pharm., Inc.

Opinion

         William P. Farley, at Karl & Tarone, Washington, DC, for plaintiff.


         MEMORANDUM ORDER

          FACCIOLA, United States Magistrate Judge.

         This case was referred to me by Judge Kennedy for full case management. Currently pending before me is the issue of whether the Office of the Senate Sergeant-at-Arms and Doorkeeper (" SAA" or " defendant" ) must produce certain documents, claimed to be privileged and submitted for in camera review, to Roy Banks (" Banks" or " plaintiff" ). For the reasons stated herein and in accordance with this Memorandum Order, the SAA must produce to plaintiff several of the documents submitted for in camera review.

         I. BACKGROUND

         Plaintiff brought this lawsuit alleging that his employer, the SAA, engaged in several unlawful employment actions. See Banks v. Office of the Senate Sergeant-at-Arms, 222 F.R.D. 7, 9 (D.D.C.2004). The parties have engaged in substantial litigation regarding discovery. In this memorandum, I resolve the issue of whether certain documents, submitted by the defendant for in camera review, can be withheld because they are covered by the work-product doctrine, the attorney-client privilege, or both.

         II. PRIVILEGES CLAIMED BY THE DEFENDANT

         A. The Work-Product Privilege

         As the Supreme Court has stated, " it is essential [to our adversarial system] that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510-11, 67 S.Ct. 385, 91 L.Ed. 451 (1947). If a lawyer's work product were " open to opposing counsel on mere demand, much of what is now put down in writing would remain unwritten. An attorney's thoughts, heretofore inviolate, would not be his own." Id. at 511, 67 S.Ct. 385.

          In light of these important interests, Federal Rule of Civil Procedure 26(b)(3) and the work-product doctrine provide that materials prepared in anticipation of litigation or for trial by an attorney or a party are protected from disclosure, and they may be subject to discovery only upon a showing of substantial need and inability to obtain the substantial equivalent without undue hardship. Fed.R.Civ.P. 26(b)(3). In addition, the court must protect the " mental impressions, conclusions, opinions, or legal theories of an attorney." Id. See also Tax Analysts v. Internal Revenue Serv., 117 F.3d 607, 619 (D.C.Cir.1997). These materials, known as opinion work product, " are entitled to special protection and require a stronger showing of necessity to justify release ... although the precise contours of this showing have not been resolved." Byers v. Burleson, 100 F.R.D. 436, 439 (D.D.C.1983) (citing Fed.R.Civ.P. 26(b)(3) and Upjohn Co. v. United States, 449 U.S. 383, 400-01, 101 S.Ct. 677, 66 L.Ed.2d 584 (1981)). See also In re Sealed Case, 856 F.2d 268, 273 (D.C.Cir.1988).

          In reviewing documents claimed to be protected by the work-product privilege, the court must determine " whether, in light of the nature of the document or the factual situation in a particular case, the document can fairly be said to have been prepared or obtained because of the prospect of litigation." Equal Employment Opportunity Comm'n v. Lutheran Soc. Servs., 186 F.3d 959, 968 (D.C.Cir.1999) (emphasis added). See also Willingham v. Ashcroft, Civ. A. No. 02-1972, 2005 WL 873223, at *2 (D.D.C. Apr.15, 2005). As I have recently noted,

[t]o be protected by the work-product doctrine, a document must have been created for use at trial or because a lawyer or party reasonably anticipated that specific litigation would occur and prepared the document to advance the party's interest in the successful resolution of that litigation. Motivation is key. In ways that cannot often be foreseen when they are created, documents may prove useful in litigation because they record an event or memorialize an occurrence. But, their creation at a time when litigation was anticipated does not automatically render them privileged. The purpose of preparing for the anticipated litigation is critical, lest the rule be interpreted to protect everything a lawyer or party does when litigation is anticipated even though the lawyer or party did not create the document to advance the client's interest in the litigation.

Willingham, 2005 WL 873223, at *2. Hence, if the same or essentially similar documents would have been created whether or not litigation was foreseen, " ‘ it [cannot] fairly be said that they were created " because of" actual or impending litigation.’ " Id. (quoting United States v. Adlman, 134 F.3d 1194, 1202-03).

         B. The Attorney-Client Privilege

          In this Circuit, " the attorney-client privilege is narrowly circumscribed to shield from disclosure only those communications from a client to an attorney made in confidence and for the purpose of securing legal advice." Willingham, 2005 WL 873223, at *6 (quoting Athridge v. Aetna Cas. & Sur. Co., 184 F.R.D. 200, 204 (D.D.C.1998)). See also Tax Analysts, 117 F.3d at 618; In re Sealed Case, 737 F.2d 94, 98 (D.C.Cir.1984). The privilege also applies to communications from attorneys to their clients if the communications " ‘ rest on confidential information obtained from the client.’ " Tax Analysts, 117 F.3d at 618 (quoting In re Sealed Case, 737 F.2d at 99 and citing Mead Data Central, Inc. v. United States Dep't of Air Force, 566 F.2d 242, 254 (D.C.Cir.1977)).

         III. SPECIFIC ISSUES REGARDING SUBSETS OF THE DOCUMENTS

         A. Documents Revealing How Counsel Investigated the Case and Prepared the Government's Defense

          Many of the documents submitted for in camera review concern a matter that defense counsel investigated when developing the facts of the case and preparing its defense. These documents were clearly prepared because of the prospect of litigation, and they reveal counsel's mental impressions and litigation strategy. Accordingly, the documents that reflect the process by which defense counsel prepared this case constitute highly protected opinion work product. Defendant's claim of work-product privilege is sustained, and defendant need not produce these documents. In the chart summarizing my rulings on each document submitted for in camera review, these materials are identified by the terms " Case Investigation and Preparation."

         B. Jane and John Doe Documents

          Several documents submitted for in camera review concern SAA employees other than Banks and the individuals who made decisions concerning the terms of his employment. Indeed, most of these documents memorialize conversations with and about a certain SAA employee, whom I shall call Jane Doe I. Other documents concern SAA employees to whom I will refer as Jane Doe II, Jane Doe III, John Doe I, and John Doe II.

         For many of these documents, the defendant claims the work-product privilege. But, neither on the face of the documents nor in the privilege log is there any showing that the documents were created because of the prospect of litigation by Banks or anyone else. Without such a showing, any claim of work-product privilege simply cannot be sustained.

          For the majority of these documents, the SAA has also claimed the attorney-client privilege. An analysis of the Jane Doe I documents reveals that the materials fall into two categories. In the first group are documents that reflect communications between the client (the SAA) and its counsel when the SAA sought legal advice regarding how to handle Jane Doe I's continued use-and possible abuse-of her sick and disability leave. A review of these documents indicates that the SAA intended the communications to be confidential, at least while the government made a determination as to whether to take disciplinary or other action. This group of documents, in which the client specifically seeks legal guidance with the understanding that its communications are confidential, is clearly protected under the attorney-client privilege.

          The second group of materials concerns the same situation. However, each of these materials does not, on its face, disclose that the client sought or an attorney rendered specific legal advice. Rather, in these documents, the SAA recounts facts so that its counsel may continue to be apprised of the developing situation and the SAA may receive continued advice from its attorneys. If the court were to deny the privilege as to these documents, it would reveal the nature of the guidance SAA sought from its counsel and, in effect, nullify the privilege that the court sustained as to the first group. Indeed, when read as a whole, it is clear that these communications were intended to be confidential and were part of the process by which the SAA sought legal advice from counsel. Indeed, " [i]t is not essential ... that [a] request for advice be express. Client communications intended to keep the attorney generally apprised of continuing business developments, with an implied request for legal advice thereon ... may also be protected." Hercules, Inc. v. Exxon Corp., 434 F.Supp. 136, 144-45 (D.Del.1977). In addition, although " it is essential that communications between client and attorney deal with legal assistance and advice in order to be privileged, it is not essential that such requests by the client for legal advice be expressed.... [Rather,] there must be a finding that each document is involved in the rendition of legal assistance." Burlington Indus. v. Exxon Corp., 65 F.R.D. 26, 37-39 (D.Md.1974). Because it can fairly be said that the documents in the second group were created to keep SAA's counsel apprised of the very situation about which the SAA sought legal assistance, the SAA's claim of attorney-client privilege, as to the second group of documents, is sustained.

         C. Chart and Abbreviated Notations

         In the interest of clarity, I have included in this memorandum two charts. The first summarizes various abbreviations I have used to describe my analysis of the materials. The second lists each document submitted for in camera review and my rulings on each privilege claim.

Abbreviated Notation

Explanation

Not for Trial

Based on information provided by defendant, thedocument cannot fairly be said to have been prepared orobtained because of the prospect of litigation or fortrial. Defendant's claim of work-product privilegeis denied.

lines

Opinion Work Product

Document can fairly be said to have been prepared fortrial or in anticipation of litigation, and it reflectscounsel's mental impressions. Defendant's claimof work-product privilege is sustained.

Ordinary Work Product

Document can fairly be said to have been prepared fortrial or in anticipation of litigation, but it does notreflect counsel's mental impressions.Defendant's claim of work-product privilege issustained, but plaintiff will have the opportunity tomake a showing of substantial need and undue hardship.

Not Confidential

Document does not disclose information that the clientintended to be confidential. Defendant's claim ofattorney-client privilege is denied.

Confidential and Seeks Legal Advice

Document reflects communications that the clientintended to be confidential and that were made for thepurposes of seeking legal advice. The attorney-clientprivilege is sustained.

Case Investigation and Preparation

These documents reveal the manner in which defensecounsel investigated and prepared the government'sdefense. The documents were prepared in anticipation oflitigation and reveal counsel's mental impressionsand litigation strategy. Defendant's claim ofwork-product privilege is sustained.

Jane Doe I, Jane Doe II, Jane Doe III, John Doe I, orJohn Doe II

These documents relate to SAA employees other thanBanks. Defendant has failed to indicate whether thesedocuments were prepared for trial or in anticipation oflitigation, either because they are related to theinstant case or to adversarial proceedings involvingother employees. Because defendant failed to make asufficient showing that these documents qualify as workproduct, the claim of work-product privilege is denied.

However, these documents do reflect confidentialcommunications made from a client (the government) toits attorney (defense counsel). Therefore, where theattorney-client privilege has been claimed, theprivilege is sustained.

Privilege

Bates #

Claimed

Ruling

Reason

RB 001735

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 001793

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 001808

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 001885

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 002004

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 002012

Attorney-client

Denied

Not Confidential

Work-product

Sustained

Ordinary Work Product

RB 002408

Attorney-client

Denied

Not Confidential

Work-product

Sustained

Ordinary Work Product

RB 002501

Attorney-client

Denied

Not Confidential

RB 002502

Attorney-client

Denied

Not Confidential

RB 002538

Attorney-client

Denied

Not Confidential

RB 002541

Work-product

Denied

While technically prepared in anticipation oflitigation, the document recounts conversations withplaintiff's counsel regarding the InitialScheduling Conference. The court will not sustaindefendant's claim of work product as to thisdocument because to do so would trivialize theprivilege.

RB 002557

Attorney-client

Denied

Not Confidential

RB 003049

Work-product

Sustained

Case Investigation and Preparation

RB 003050-

Work-product

Sustained

Case Investigation and Preparation

RB 003051

RB 003056-

Work-product

Sustained

Case Investigation and Preparation

RB 003058

RB 003060-

Work-product

Sustained

Case Investigation and Preparation

RB 003062

RB 003066

Work-product

Sustained

Case Investigation and Preparation

RB 003067

Work-product

Sustained

Case Investigation and Preparation

RB 003068

Work-product

Sustained

Case Investigation and Preparation

RB 003095

Work-product

Sustained

Case Investigation and Preparation

RB 003096

Work-product

Sustained

Case Investigation and Preparation

RB 003111

Work-product

Sustained

Case Investigation and Preparation

RB 003112

Work-product

Sustained

Case Investigation and Preparation

RB 002417

Work-product

Denied

Not for Trial

RB 002993-

Work-product

Sustained

Opinion Work Product

RB 002994

RB 003113-

Work-product

Sustained

Case Investigation and Preparation

RB 003122

RB 003123

Work-product

Sustained

Case Investigation and Preparation

RB 003129-

Work-product

Sustained

Opinion Work Product

RB 003131

RB 003687

Work-product

Sustained

Opinion Work Product

RB 003738

Attorney-client

Denied

Not Confidential

RB 003757

Attorney-client

Denied

Not Confidential

Work-product

Denied

Insufficient showing of whether this draft letter to anunnamed individual was prepared in anticipation oflitigation

RB 004186-

Work-product

Sustained

Opinion Work Product

RB 004187

RB 004604-

Attorney-client

Denied

Case Investigation and Preparation

RB 004608

Work-product

Sustained

RB 004612

Work-product

Sustained

Opinion Work Product

RB 006235-

Work-product

Sustained

Case Investigation and Preparation

RB 006239

RB 007037

Attorney-client

Denied

Case Investigation and Preparation

Work-product

Sustained

RB 007038-

Work-product

Sustained

Case Investigation and Preparation

RB 007040

RB 007041-

Work-product

Sustained

Case Investigation and Preparation

RB 007042

RB 007043

Work-product

Sustained

Case Investigation and Preparation

RB 007044

Attorney-client

Denied

Not Confidential

Work-product

Denied

Not for Trial

RB 008418

Work-product

Denied

Not for Trial

RB 004188-

Work-product

Sustained

Opinion Work Product

RB 004193

RB 008542-

Attorney-client

Sustained

Jane Doe I

RB 008543

Work-product

Denied

RB 008552-

Attorney-client

Sustained

Jane Doe I

RB 008554

Work-product

Denied

RB 008559-

Attorney-client

Sustained

Jane Doe I

RB 008562

Work-product

Denied

RB 008563-

Attorney-client

Sustained

Jane Doe I

RB 008564

Work-product

Denied

RB 008570

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008587

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008588-

Attorney-client

Sustained

Jane Doe I

RB 008589

Work-product

Denied

RB 008592

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008593

Attorney-client

Sustained

Jane Doe I

RB 008594

Attorney-client

Sustained

Jane Doe I

RB 008626

Attorney-client

Sustained

Jane Doe I

RB 008627

Attorney-client

Sustained

Jane Doe I

RB 008663

Attorney-client

Sustained

Jane Doe I

RB 008907-

Attorney-client

Sustained

Jane Doe I

RB 008908

Work-product

Denied

RB 008909

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008558

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008919

Attorney-client

Denied

Not Confidential

RB 008925

Attorney-client

Denied

Not Confidential

RB 008928-

Work-product

Denied

Jane Doe II

RB 008930

RB 008931-

Work-product

Denied

Jane Doe II

RB008932

RB 008941

Attorney-client

Denied

Case Investigation and Preparation

Work-product

Sustained

RB 008942

Work-product

Sustained

Case Investigation and Preparation

RB 008944

Attorney-client

Denied

Not Confidential

RB 008956

Work-product

Denied

Jane Doe III

RB 008957-

Work-product

Denied

John Doe I

RB 008962

RB 009415

Attorney-client

Denied

Case Investigation and Preparation

Work-product

Sustained

RB 009416

Attorney-client

Denied

Case Investigation and Preparation

Work-product

Sustained

RB 009417-

Attorney-client

Denied

Case Investigation and Preparation

RB 009419

Work-product

Sustained

RB 012245

Attorney-client

Sustained

John Doe II

RB 013332

Attorney-client

Denied

Not Confidential

RB 013352-

Work-product

Sustained

Opinion Work Product

RB 013353

RB 013451-

Work-product

Sustained

Case Investigation and Preparation

RB 013452

RB 013714

Work-product

Sustained

Case Investigation and Preparation

RB 013793

Attorney-client

Sustained

Confidential and Seeks Legal Advice

Work-product

Sustained

Opinion Work Product

RB 013794

Attorney-client

Denied

Not Confidential

Work-product

Sustained (in part)

Opinion Work Product (in part)

RB 013804

Work-product

Sustained

Opinion Work Product

RB 013805

Work-product

Sustained

Opinion Work Product

RB 013806-

Work-product

Sustained

Opinion Work Product

RB 013812

RB 013813-

Work-product

Sustained

Opinion Work Product

RB 013823

RB 013824-

Work-product

Sustained

Opinion Work Product

RB 013828

RB 013829-

Work-product

Sustained

Opinion Work Product

RB 013830

RB 013863-

Work-product

Sustained

Opinion Work Product

RB 013864

RB 013865-

Work-product

Sustained

Opinion Work Product

RB 013866

RB 013873-

Attorney-client

Denied

Not Confidential

RB 013874

Work-product

Sustained (in part)

Opinion Work Product (in part)

RB 013875-

Work-product

Sustained

Opinion Work Product

RB 013878

RB 013879-

Attorney-client

Sustained

Confidential and Seeks Legal Advice

RB 013880

RB 014815-

Attorney-client

Denied

Not Confidential

RB 014816

RB 014937

Work-product

Sustained

Opinion Work Product

RB 014939-

Work-product

Sustained

Opinion Work Product

RB 014940

RB 015144

Attorney-client

Denied

Not Confidential

RB 015147

Work-product

Sustained

Ordinary Work Product

RB 008476

Work-product

Denied

Jane Doe I

RB 008439

Attorney-client

Sustained

Jane Doe I

RB 008477

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008478

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008483

Work-product

Denied

Jane Doe I

RB 008487

Attorney-client

Sustained

Jane Doe I

RB 008488-

Work-product

Denied

Jane Doe I

RB 008490

RB 008491-

Attorney-client

Sustained

Jane Doe I

RB 008493

Work-product

Denied

RB 008499

Attorney-client

Sustained

Jane Doe I

RB 008507

Attorney-client

Sustained

Jane Doe I

RB 008508

Attorney-client

Sustained

Jane Doe I

RB 008509

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008510

Attorney-client

Sustained

Jane Doe I

RB 008511

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008512

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008479

Attorney-client

Sustained

Jane Doe I

RB 008480

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008481

Attorney-client

Sustained

Jane Doe I

RB 008482

Attorney-client

Sustained

Jane Doe I

RB 008484

Attorney-client

Sustained

Jane Doe I

RB 008485

Attorney-client

Sustained

Jane Doe I

RB 008486

Attorney-client

Sustained

Jane Doe I

RB 008494

Attorney-client

Sustained

Jane Doe I

RB 008495

Attorney-client

Sustained

Jane Doe I

RB 008496

Attorney-client

Sustained

Jane Doe I

RB 008497

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008498

Attorney-client

Sustained

Jane Doe I

RB 008500

Attorney-client

Sustained

Jane Doe I

RB 008502

Attorney-client

Sustained

Jane Doe I

RB 008503

Attorney-client

Sustained

Jane Doe I

RB 008504

Attorney-client

Sustained

Jane Doe I

RB 008505

Attorney-client

Sustained

Jane Doe I

RB 008506

Attorney-client

Sustained

Jane Doe I

RB 008513

Attorney-client

Sustained

Jane Doe I

RB 008443-

Attorney-client

Sustained

Jane Doe I

RB 008444

Work-product

Denied

RB 008445

Attorney-client

Sustained

Jane Doe I

RB 008446

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008447

Attorney-client

Sustained

Jane Doe I

RB 008448

Work-product

Denied

Jane Doe I

RB 008449

Work-product

Denied

Jane Doe I

RB 008455-

Attorney-client

Sustained

Jane Doe I

RB 008456

Work-product

Denied

RB 008457

Attorney-client

Sustained

Jane Doe I

RB 008458

Attorney-client

Sustained

Jane Doe I

RB 008459

Attorney-client

Sustained

Jane Doe I

RB 008460

Attorney-client

Sustained

Jane Doe I

RB 008461

Attorney-client

Sustained

Jane Doe I

RB 008462

Attorney-client

Sustained

Jane Doe I

RB 008465

Attorney-client

Sustained

Jane Doe I

RB 008467

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008468

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008469-

Attorney-client

Sustained

Jane Doe I

RB 008470

Work-product

Denied

RB 008471

Attorney-client

Sustained

Jane Doe I

work product

Denied

RB 008472

Attorney-client

Sustained

Jane Doe I

RB 008473

Attorney-client

Sustained

Jane Doe I

RB 008474

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008475

Attorney-client

Sustained

Jane Doe I

Work-product

Denied

RB 008441

Work-product

Denied

Jane Doe I

RB 008451

Attorney-client

Sustained

Jane Doe I

RB 008452

Attorney-client

Sustained

Jane Doe I

RB 008453

Attorney-client

Sustained

Jane Doe I

RB 008454

Attorney-client

Sustained

Jane Doe I

RB 008463

Attorney-client

Sustained

Jane Doe I

RB 008464

Attorney-client

Sustained

Jane Doe I

RB 008466

Attorney-client

Sustained

Jane Doe I

RB 014230-

Work-product

Sustained

Opinion Work Product

RB 014236

RB 014241-

Work-product

Sustained

Opinion Work Product

RB 014247

RB 014263-

Attorney-client

Sustained as to

Opinion Work Product

RB 014269

Work-product

work product

RB 014289-

Attorney-client

Sustained as to

Opinion Work Product

RB 014290

Work-product

work product

E-mail from Pence dated 5/28/04

Work-product

Sustained

Opinion Work Product

Memo to file dated 7/15/03

Work-product

Sustained

Opinion Work Product

Memo to file dated 7/25/03

Work-product

Sustained

Opinion Work Product

         IV. CONCLUSION

The first sentence of the second paragraph is opinion work product. Therefore, the document must be produced, but only after that sentence has been redacted.

The first sentence of the second paragraph is opinion work product. Therefore, the document must be produced, but only after that sentence has been redacted.

         For the reasons stated herein, the defendant is, hereby, ORDERED to, within 10 days of this Memorandum Order, produce all of the documents as to which its claim of privileges have been denied. As to those documents for which the court has sustained the claims of privilege in part, defendant shall produce redacted versions of the materials to plaintiff. For documents determined to be ordinary work product, the court has provided a more detailed description than appears in the privilege log so that plaintiff, if he chooses, may articulate his substantial need for the materials and his inability to secure the substantial equivalent without undue hardship. Any such showing must be made, in writing, by May 16, 2005. Defendant may respond by May 23, 2005. The court notes that these documents are hardly earth-shattering in their significance and hopes that, in a case in which so much money has already been spent on discovery, the parties can work together to determine whether additional litigation over these three documents is in anyone's interest.

These descriptions appear in Appendix A.

         SO ORDERED.

         Appendix A

The following contains a description of all thedocuments found to be ordinary work product.

RB 002012

This document is a memorandum from Catherine Brooks(" Brooks" ), Administrator, SenateWorkers' Compensation Program, to Brenda Pence,Senior Counsel. The memorandum concerns an inventorylog that Brooks received from S.R.

RB 002408

This document is an email from Claudia Kostel to JeanMcComish. It concerns how to follow up with Banksregarding his FMLA forms.

RB 015147

This document is an email from Brenda Pence to KathleenJoseph. It concerns Banks' appeals of hisworkers' compensation claims.


Summaries of

Banks v. Office of Senate Sergeant-At-Arms

United States District Court, D. Columbia
May 9, 2005
228 F.R.D. 24 (D.D.C. 2005)

finding that documents which did not on their face contain requests for legal advice were nevertheless protected because they were compilations of facts for use by counsel in providing legal advice

Summary of this case from Fed. Trade Comm'n v. Boehringer Ingelheim Pharm., Inc.
Case details for

Banks v. Office of Senate Sergeant-At-Arms

Case Details

Full title:ROY BANKS, Plaintiff, v. OFFICE OF THE SENATE SERGEANT-AT-ARMS and…

Court:United States District Court, D. Columbia

Date published: May 9, 2005

Citations

228 F.R.D. 24 (D.D.C. 2005)

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