Court of Appeals Clarifies Reach of Attorney-Client Privilege With Respect To Internal Investigation Documents
On June 27, 2014, the United States Court of Appeals for the District of Columbia Circuit overturned Barko v. Halliburton, a recent district court decision concluding that certain reports generated as a result of a company’s internal investigation were not protected from disclosure by the attorney-client privilege because they were not created for the primary purpose of seeking or providing legal advice.