Discovery Advocate
The Supreme Court Dodges—for Now—the Circuit Split on the ‘Dual Purpose' Test for Privilege
By Csilla Boga-Lofaro, David Choi, Edward J. Jacobs, Jennifer C. Negron
February 21, 2023
In re Grand Jury, 23 F.4th 1088 (9th Cir. 2022), appeal dismissed as improvidently granted, In re Grand Jury, 598 U.S. ____ (2023) (No. 21-1397). Summary of the Case: The Supreme Court, which had initially agreed to consider a circuit...
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