Article: Massachusetts Supreme Judicial Court Upholds Use Of Work Product Doctrine To Protect Documents.

On March 3, 2009, the Massachusetts Supreme Judicial Court upheld the trial court's determination that memoranda prepared by an accounting firm at the request of in-house counsel were protected as work product. Commissioner of Revenue v. Comcast Corp., SJC-10209 (Mass. Mar. 3, 2009). The court, however, rejected the trial court's holding that the attorney-client privilege protected the memoranda.

Background In an unpublished decision, the Massachusetts Superior Court had held that certain documents prepared by the accounting firm Arthur Andersen were protected under both the attorney-client privilege and the work product doctrine. The Commissioner of Revenue, ...

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