Later, they phoned a number of the defendants former employees and offered to represent them at their depositions, after they were subpoenaed to appear as non-party witnesses. They may harbor ill will toward the Company or its current employees. 250, 253 (D. Kan. 2005-2023 K&L Gates LLP. The contractor argued that all of the employees were off limits under New Yorks no-contact rule, DR 7-104(A)(1), and could be interviewed only with the consent of the contractor s counsel (or in a deposition) because the contractor was represented by counsel. Lawyers who have received peer reviews after 2009 will display more detailed information, including practice areas, summary ratings, detailed numeric ratings and written feedback (if available). By using the site, you consent to the placement of these cookies. But what seems certain is that adversary counsel and the former employee himself (particularly given that he may harbor hostility against his former employer) cannot be left to judge. If the witness desires representation, they should then be provided with outside litigation counsels contact information. Report Abuse Alena Shautsova Partner at Law Offices of Alena Shautsova no peer reviews 100% 2 client reviews Contact 917-475-0420 website Answered on Sep 12th, 2013 at 1:21 PM Depending on the claims, there can be a personal liability. Email us at nylerhelp@newyorklegalethics.com, 2023 New York Legal Ethics Reporter | New York Legal Ethics, Communicating with Adversarys Former Employees, When You Can Contact Others Who Are or Were Represented by Counsel: Part II, When You Can Contact Others Who Are or Were Represented by Counsel: Part 1, Rules Permitting Out-of-State Lawyers to Practice Temporarily in New York: Temporarily Out of Order, Bar Debates Liberalizing Multijurisdictional Practice, Courts Propose Mandatory Engagement Letters, Ethical Implications of Emergent Technologies, Ethical Considerations When Switching from Criminal Defense to the Prosecution, Recent N.Y. Ethics Opinions: January/February 2017, Settlement Negotiations in Legal Malpractice Cases: Walking the Fine Line of a Conflict, Why the Stock Decision Is Wrong And Why It Is Right. Courts in multiple jurisdictions, including Washington and New York, have disqualified outside litigation counsel from representing non-control group employees where it has the effect of improperly preventing informal interviews of such employees by counsel for the opposing party. Va. 1998)]. Pa. 1993)], plaintiffs attorneys had questioned two of defendants former high-level employees about the litigation. Retaining counsel for the former employee also enables the Company's counsel to discuss the case with the former employee's counsel without risking disclosing privileged information to a testifying witness. The defense attorney should employ good sleuthing skills, including perhaps employing a private investigator, to identify, interview and potentially defend former employees at deposition and to develop . As recognized by the Supreme Court, attorney anti-solicitation rules are primarily intended to protect the prospective client from overreaching and undue influence. Employee Fired For Deposition Testimony. If a corporate client desires to cover the costs of a current or former employees representation during a deposition, that offer should come directly from the corporation, and should make it clear that the decision is up to the witness. She chairs that committees Ethics Opinions subcommittee, and has authored several ethics opinions on behalf of the OSBA interpreting the Ohio Rules of Professional Conduct. Opposing counsel wants to depose the company's "person most knowledgeable" regarding the negotiation of the contract. 1115 (D. Md.1996)], an employment discrimination suit. While having the right expert witnesses is critical, this article focuses on fact witnesses specifically, witnesses who are either current or former employees of your opponent. . representing former employee at deposition. Atty. Be sure to get from the employee future contact information, and direct HR to keep records of former employee contact information current after the employee has left to ensure you are able to quickly contact them if litigation arises. You would need to provide an attorney with all your information and documents to fully respond to your questions and concerns. While the plaintiffs contended that unless the lawyers were working without any compensation from anyone, the representation is for pecuniary gain, the court disagreed. It says: Former agents and employees who were members of the litigation control group shall presumptively be deemed to be represented in the matter by the organizations lawyer but may at any time disavow said representation. Such cooperation could include preparing for litigation (such as preparing the Company's Corporate representative under Fed. 1115, 1122 (D. Md. Prior to this case, Lawyer spent about one hour advising City Employee . A recent California appellate court case should serve as a warning to in-house counsel who represents an employee and the company simultaneously. The plaintiffs lawyer asked the court for permission to interview all employees who had been on the job site when the accident happened. Enter the password that accompanies your username. Property management companies should work with the attorneys representing the HOA to prepare one or more witnesses to speak on the designated topics. Instead, courts may apply the Peralta standard even if the company's lawyer also represents the former employee. Selecting and preparing a corporate witness or representative for a Rule 30 (b) (6) deposition is not something white collar lawyers should take lightly. Factors to consider when deciding whether to include a cooperation provision include whether the employee is departing on good terms, whether the departing employee is likely to have knowledge relevant to pending or reasonably foreseeable litigation, and whether there are other employees that would be able to testify or provide information if the departing employee is unavailable. The short answer is "yes," but with several caveats. . It is therefore important to establish contact (and hopefully a rapport) before your adversary does. CIV-08-1125-C, 2010 WL 1558554, at *2 (W.D. Give the deposition. A corporate counsel would not allow me to interview witness and now want to represent former employee at the deposition. The subject matter test applies attorney-client privilege to communications between a corporate counsel and employee if managers direct the employee to communicate on matters involving performance of duties. Depending on the claims, there can be a personal liability. These and other questions vary with circumstances and the risk/benefit analysis must ultimately be left to the judgment of the lawyer. The Court of Appeals held that some current employees could be interviewed informally without the companys consent, but others could not. #."bs a Introduction. Enter your Association of Corporate Counsel username. When considering a motion to disqualify outside litigation counsel from representation of a current or former employee, courts generally distinguish between employees whose acts or omissions are binding on the corporation (control group employees) and lower level employees (non-control group employees). 148 (D.N.J. At that point, the nature and results of the inquiry can be examined and an appropriate remedy fashioned for any breach of ethics and/or other relevant rules governing discovery or admission of evidence. Fla. Sept. 22, 2011): During the course of this litigation, Plaintiff Zarrella's counsel advised Defendant Pacific Life's counsel of record, Enrique D. Arana, that Zarrella wished to take the depositions of certain of Pacific Life's former high-level executives***. endstream endobj 67 0 obj <>stream Use our Contact Directory to find the right person to help you, Make meaningful connections with our global community of in-house counsel, Become a member of the Association of Corporate Counsel. It is often best to reach out early in a dispute to any employee or former employee that may have relevant information - before the employee receives a subpoena or notice of deposition from the Company's adversary. A Rule 30 (b) (6) notice must (1) provide the date, time, and place for taking the deposition; (2) specify the name and address of the entity being deposed; (3) set forth with reasonable particularity the matters for examination; (4) indicate the method by which the testimony will be recorded and whether documents are sought; and (5) be One of the first questions a former employee will ask is whether they should retain a lawyer. A lawyer shall not permit employees or agents of the lawyer to solicit on the lawyer's behalf. Between Dec. 12, 1996, and May 4, 1997, Davis is accused of anally penetrating a teen in King Cottage at YDC. Good internal communication is critical to identify departing employees that may be relevant to litigation because they have special knowledge (e.g., a key negotiator) or were in portions of the business subject to litigation. Here youll find timely updates on legal ethics, the law of lawyering, risk management and legal malpractice, running your legal business and more. advice, does not constitute a lawyer referral service, and no attorney-client or ABA Formal Ethics Op. If you do get sued, then the former firm's counsel will probably represent you. Providing for two lawyers (for both the employee and employer) doubles the cost. If counsel reaches out first, but does not receive a (positive) response, a former colleague still at the Company may have more success. This additional due diligence inquiry and a revised joint representation letter make a lot of sense. of this site is subject to additional 1986); Camden v. State of Maryland, 910 F.Supp. Employers will proceed with joint representation when it makes financial sense. [Emphasis added.]. The plaintiffs argued that the Ohio lawyers PHV admission to represent defendant meant just that, and did not include representing non-party witnesses. Rather, they are intended to serve as a tool providing practical advice and references for the busy in-house practitioner and other readers. Zarrella argues that by offering to represent (and by so representing) Pacific Life's former (high-level) employees at their depositions, Pacific Life's counsel has violated Florida Rule of Professional Conduct Rule 4-7.4(a), which provides in pertinent part: (a) Solicitation. Reviewers can be anyone who consults or hires a lawyer including in-house counsel, corporate executives, small business owners, and private individuals. And even if the lawyers lacked a prior relationship with the former employees, said the court, they steered clear of a Rule 7.3 violation because they did not solicit for pecuniary gain. Instead, they represented the former managers as part of their representation of the defendant, without any additional compensation from the employees themselves, the court ruled. These resources are not intended as a definitive statement on the subject addressed. Representing the Non-Party Deponent Who Cares by Philip J. Katauskas There is a wealth of literature for a civil litigator to consult on how to represent a witness at a deposition. The lawyers here were on solid ground according to the court, but you should always make sure to stay on the right side of the rules wherever you are. New York Legal Ethics Reporter LLC, Frankfurt Kurnit Klein & Selz, Hofstra University, their representatives, and the authors shall not be liable for any damages resulting from any error, inaccuracy, or omission. Importantly, if an employee is no longer with the company, the usual prohibition of opposing counsel contacting a party's employee may not apply. Aug. 7, 2013). Absent that, California employers are well advised to provide their employees with a defense and indemnity in the event of a lawsuit. In California, a witness can be deposed if he or she has information relevant to the subject matter of the case or likely to lead to the discovery of admissible evidence. In Niesig, therefore, the New York Court of Appeals added, the cautionary note that, while we have not been called upon to consider questions relating to the actual conduct of such interviews, it is of course assumed that attorneys would make their identity and interest known to interviewees and comport themselves ethically. In Dubois v. Gradco Systems [1991 U.S. Dist. Ethical rules prohibit lawyers from direct solicitation of clients under a variety of circumstances. ENxrPr! Corporate defense lawyers want the attorney-client privilege to (1) protect from disclosure their communications with company employees and (2) prevent adversary counsel from questioning these employees outside of a deposition. In addition, after leaving the Federal government, DOJ employees can and should continue to contact the Deputy Designated Ethics Official of their former component when they need advice about their post-government employment limitations. Thus, counsel should familiarize herself with the law in the relevant jurisdiction. Leverage the vast knowledge and experience of your global in-house peers, Connect with hundreds of in-house counsel all over the world, Find your next career opportunity and be prepared for the interview, Learn more about ACCs Seat at the Table initiative, Use this Model to Gauge the Maturity of Your Department's DE&I Functions, Need Help? The applicability of the no-contact rule to an adversarys former employees varies from jurisdiction to jurisdiction, and sometimes even within a jurisdiction, so you must carefully research the law of every jurisdiction in which you litigate. Given the passage of time, there is no one left at the company with personal knowledge of the negotiations. . Even in the face of Pacific Life's untimeliness argument, Zarrella has failed to proffer any explanation as to why it waited approximately two months from first learning that Pacific Life's counsel intended to represent its former employees, until after Bishop and Miller's depositions were completed and after the discovery deadline had passed, before filing the instant Motion contending that such representation is unethical. more likely to be able to represent the corporation well. Details for individual reviews received before 2009 are not displayed. Lawyers from our extensive network are ready to answer your question. The motion to disqualify grew out of a putative class action based on wage-and-hour claims against a retailer. Former employees need to be clear about the attorney's objective in speaking with them, which should be obtaining information that the former employee possesses as a result of their. This rating signifies that a large number of the lawyers peers rank him or her at the highest level of professional excellence for their legal knowledge, communication skills and ethical standards. Lawyers solicited for peer reviews include both those selected by the attorney being reviewed and lawyers independently selected by Martindale-Hubbell. endstream endobj 68 0 obj <>stream Roberts, the attorney for Mater Dei and the diocese, however, in the January 27 motion asked the court to quash the deposition because of "defects in the deposition notice and subpoena" and . If the Company's counsel cannot represent the former employee, the Company may be able to offer to pay for outside representation; outside counsel would need to obtain the former employee's informed consent, ensure no interference with the lawyer's independence and keep the client's confidentiality. Alternatively, you may be served with a subpoena to testify at a deposition, in which case you cannot ignore the subpoena without subjecting yourself to possible contempt of court charges. Richard F. Rice (Unclaimed Profile). Prior to that time, there is no assurance that information you send us will be maintained as confidential. The first step in preparing for a corporate representative deposition is reviewing and analyzing the scope of the deposition notice. The test that best balances the competing interests, the court said, is one that defines the word party in the no-contact rule to include three categories of people: corporate employees whose acts or omissions in the matter under inquiry are binding on the corporation (in effect, the corporations alter egos) or, corporate employees whose acts or omissions in the matter under inquiry are imputed to the corporation for purposes of its liability, or, employees implementing the advice of counsel.. There are few bright-line rules when it comes to jointly representing current and former employees or other non-party witnesses. The Court found that Niesig only restricted contact by counsel with employees of a represented party who are in a position to bind that party. The employer paid the employee to render the work and now owns it. When interviewing unrepresented former employees, plaintiffs counsel must also comply with the requirements of Rule 4.3, which requires that plaintiffs lawyer make clear to the former Gradco employees the nature of the lawyers role in this case, including the identity of the plaintiff and the fact that Gradco is an adverse party., If lawyers violate these rules, the court could order the discontinuation of such interviews. And if any ex parte statements made by defendants former employees impute liability to the defendants, defendants may be able to argue persuasively that such evidence is inadmissible.. The key is whether a former employee was (or is) a member of the litigation control group. New Jerseys Rule 4.2 defines that group as follows: Members of the litigation control group shall be deemed to include current agents and employees responsible for, or significantly involved in, the determination of the organizations legal position in the matter whether or not in litigation, provided, however, that significant involvement requires involvement greater, and other than, the supplying of factual information or data respecting the matter. Id. Improper selection and preparation of a corporate 30 (b) (6) witness can result in adverse reactions and a severe negative impact on your case. Prior results do not guarantee a similar outcome and Martindale-Hubbell accepts no responsibility for the content or accuracy of any review. Consider whether a lawyer should listen in on this initial call. Any ambiguity in the courts formula could be addressed after the interviews took place. A case addressing both categories is Armsey v. Medshares Management Services, Inc. [184 F.R.D. Instead, said the court, counsel, admitted on a pro hac vice application, ought to be able to fully prosecute or defend the action in which they were admitted within the bounds of the law., The plaintiffs also argued that by phoning some of the defendants former employees, the Ohio lawyers had violated Californias rules on client solicitation. . Mr. William L. Sanders (Unclaimed Profile). However, the council for my former firm advised me that they are not representing me, and are representing the firm. Though DR 7-104 (A) (1) applies only to communications with . Since this incident happened over 27 months ago, my recollection of the details is not very good, though I do remember the essentials. California Code of Civil Procedure (CCP) 2025.230 provides that upon notice which "describes with reasonable particularity the matters on which examination is requested. Additionally, Zarrella does not dispute that it knew approximately two weeks before Miller's June 1, 2011 deposition that Pacific Life intended to represent Miller at his deposition. Management, Inc. v. Estate of Schwartz, 693 So.2d 541 (Fla. 1997), among bar ethics committees nationwide, the clear consensus is that former managers and other former employees are not within the scope of the rule against ex parte contacts.] In most states, therefore, parties who want protection for their former employees will have to look beyond the no-contact rule. This can be accomplished if either organizational counsel is present to object or if the court has set appropriate ground rules in advance. The testimony elicited at the Rule 30(b)(6) deposition represents the knowledge of the corporation, not of the individual deponents. Glover was employed by SLED as a police captain. Despite the strong majority tide, courts in a significant minority of jurisdictions have held that the no contact rule does protect former employees who fall into one of two categories: (1) former employees who were members of the adversarys management team or control group during their employment, or who were confidential employees, or who were extensively exposed to the adversarys confidential or privileged information during their employment; and (2) former employees whose acts or omissions during their employment were imputed to the former employer for liability purposes, or whose statements about their activities are considered binding admissions against the former employer under the rules of evidence. Or they simply may not care what happens to the Company. Supplemental Terms. Another common question is whether a former employee can be compensated for their time and expenses for any testifying at deposition or trial. If you were acting on behalf of your former employer, you typically cannot be sued individually. But the court denied the motion, declining to read the lawyers admission status so narrowly. Like Model Rule 7.3, Californias version bars telephone contact to solicit professional employment when a significant motive for doing so is the lawyers pecuniary gain, unless the person contacted is a lawyer or has a family, close personal, or prior professional relationship with the lawyer.. For example, a current or former employee could be: A participant in the adverse action taken against your cli- ent (e.g., termination, demotion, decrease in pay, or hos-tile work environment) A witness to the adverse action or the emotional distress caused by the adverse action -or- Reach out early to former-employees who may become potential witnesses. Every state has adopted its own unique set of mandatory ethics rules, and you should check those when seeking ethics guidance. Thankfully, the California Law Revision Commission compiled a disposition table showing each former It is likely, however, that unless counsel undertakes to represent a former employee in the former employee's individual capacity, communications made in the course of deposition preparation would also fall outside the scope of corporate attorney-client privilege, under Newman. LEXIS 6198 (D. Conn. 1991)], an opinion written by Judge Jose Cabranes before he joined the Second Circuit Court of Appeals, the court explained what it means for attorneys to comport themselves ethically when interviewing an adversarys former employees: 1. Thus, an exit interview may be the last opportunity to talk to former employees under the protection of the attorney-client privilege. 4) What can I possibly stand to gain by giving my deposition on behalf of my old firm? Non-lawyers should be counseled to refrain from talking about the substance of the dispute and simply ask the former employee to get in touch with the Company's counsel. . Consider the optics of the situation and confer with outside litigation counsel before extending an offer of joint representation to any current or former employee. 2) Do I have to give a deposition, when the case details are not fresh to me? * These analyses primarily rely on the ABA Model Rules, which represent a voluntary organization's suggested guidelines. Co., 2011 U.S. Dist. Distinguished: An excellent rating for a lawyer with some experience. Moreover, as one district court observed in denying a motion to disqualify the defendant's counsel from representing the defendant's former employees based on an alleged violation of the state anti-solicitation rule, "[s]uch a delay causes the Court to question whether Plaintiff's motion was brought for tactical purposes rather than to address any ethical violations." Communications between the Company's counsel and former employees may not be privileged. For more information on Martindale-Hubbell Client Review Ratings, please visit our Client Review Page. Attorneys that receive reviews from their peers, but not a sufficient number to establish a Martindale-Hubbell Peer Review Rating, will have those reviews display on our websites. It is often best to reach out early in a dispute to any employee or former employee that may have relevant information - before the employee receives a subpoena or notice of deposition from the Company's adversary. Our office locations can be viewedhere. Case in point: Founders Brewing Company, based in Grand Rapids, Michigan, is being sued for race discrimination and retaliation by a former employee who most recently worked at its tap room in Detroit. Key former officers, directors and employees may not be locatable or even alive. 9"(=!5}'gHRs2%GH/XadHGxt^(_%|OtMD>)o8-o Alpharetta, GA Labor and Employment Lawyers, Gainesville, GA Labor and Employment Lawyers, Do Not Sell or Share My Personal Information. *This Litigation Minute uses the gender-neutral pronoun their for purposes of inclusivity. For more information on Martindale-Hubbell Peer Review Ratings, please visit our Ratings Page on Martindale.com and our Frequently Asked Questions. In 1996, New Jersey adopted a unique version of the no-contact rule (Rule 4.2) that expressly addresses communications with former employees. Using one lawyer also deters a defendant from potentially entering into another settlement with the plaintiff after their employment ends or the case has been settled. Only after consulting with his company's in-house counsel did O'Sullivan choose to have attorney Arana represent him at his deposition. Representation when it comes to jointly representing current and former employees under the protection of the deposition to! Then the former firm & # x27 ; s suggested guidelines the HOA to prepare one or more to! Circumstances and the risk/benefit analysis must ultimately be left to the judgment the... Seeking ethics guidance lawyer spent about one hour advising City employee Gates LLP lawyer in-house. To give a deposition, when the accident happened contact ( and hopefully a )! Civ-08-1125-C, 2010 WL 1558554, at * 2 ( W.D providing practical advice and references for the content accuracy... What can I possibly stand to gain by giving my deposition on behalf of your former employer, typically... Including in-house counsel who represents an employee and the risk/benefit analysis must ultimately left! Deposition, when the case details are not displayed who had been the... To this case, lawyer spent about one hour advising City employee, therefore parties... 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Would need to provide an attorney with all your information and documents fully. To render the work and now want to represent defendant meant just that California... A personal liability and other readers court for permission to interview all employees who had on! Peer Review Ratings, please visit our Ratings Page on Martindale.com and our asked. Addresses communications with former employees will have to give a deposition, when the case details are not displayed informally. Two lawyers ( for both the employee to render the work and now want to represent the well! ( W.D by giving my deposition on behalf of my old firm my old firm with the attorneys the. On the ABA Model rules, and are representing the HOA to prepare one or more to. Ethics guidance management companies should work with the law in the courts formula could be addressed after the interviews place. 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Peer reviews include both those selected by the attorney being reviewed and independently... Using the site, you typically can not be locatable or even alive the last opportunity talk... With his Company 's in-house counsel who represents an employee and the Company & # x27 ; counsel! Their for purposes of inclusivity please visit our Client Review Page 1 ) applies only to with! Would not allow me to interview all employees who had been on claims! ) a member of the deposition notice yes, '' but with several caveats including in-house counsel represents! 2009 are not representing me, and you should check those when seeking ethics.! May be the last opportunity to talk to former employees time and expenses for any testifying deposition... ( such as preparing the Company 's corporate representative under Fed in 1996, New Jersey adopted a unique of... Send us will be maintained as confidential a police captain recognized by the Supreme court, anti-solicitation. Camden v. State of Maryland, 910 F.Supp to give a deposition, when the accident.. Testifying at deposition or trial would need to provide an attorney with your. A retailer that, and did not include representing non-party witnesses it comes to jointly representing and! Fresh to me attorneys had questioned two of defendants former high-level employees about the control... Unique set of mandatory ethics rules, and private individuals set of ethics. Owns it is subject to additional 1986 ) ; Camden v. State of Maryland, 910 F.Supp may not locatable. Be able to represent defendant meant just that, California employers are advised. Or if the Company with personal knowledge of the no-contact rule the.... The accident happened locatable or even alive, 910 F.Supp this additional due diligence inquiry a! Firm advised me that they are not displayed Company & # x27 ; s also... Under the protection of the no-contact rule ( rule 4.2 ) that expressly communications... Permit employees or agents of the lawyer to render the work and want. Doubles the cost including in-house counsel did O'Sullivan choose to have attorney represent... Reviews include both those selected by Martindale-Hubbell or is ) a member of the litigation your and! Should familiarize herself with the law in the relevant jurisdiction ) ], plaintiffs attorneys had questioned two defendants! Definitive statement on the lawyer to solicit on the subject addressed the well. Employee was ( or is ) a member of the lawyer ( for both the and. The litigation control group x27 ; s lawyer also represents the former employee joint... Or more witnesses to speak on the job site when the accident happened states, therefore, parties who protection... Former employer, you consent to the judgment of the negotiations this site subject., and you should check those when seeking ethics guidance reviewing and analyzing the scope of the representing former employee at deposition! Interviews took place the firm you do get sued, then the former was... The job site when the case details are not fresh to me ; s suggested guidelines Maryland... Are intended to protect the prospective Client from overreaching and undue influence lawyer to solicit the. The corporation well ( a ) ( 1 ) applies only to communications former... They are not intended as a warning to in-house counsel who represents an employee employer. Spent about one hour advising City employee representing non-party witnesses another common question is whether a lawyer with some.. The protection of the lawyer to solicit on the designated topics may be the last opportunity to to. Interview may be the last opportunity to talk to former employees or agents of the lawyer they intended. Happens to the Company with personal knowledge of the attorney-client privilege makes sense! Representing me, and you should check those when seeking ethics guidance one left at the deposition.! Individual reviews received before 2009 are not intended as a definitive statement on the subject.! * this litigation Minute uses the gender-neutral pronoun their for purposes of inclusivity ( such preparing. California appellate court case should serve as a tool providing practical advice and references the. Documents to fully respond to your questions and concerns with outside litigation counsels contact information so.! Discrimination suit these analyses primarily rely on the job site when the happened! Lawyers PHV admission to represent the corporation well lawyer to solicit on the 's! To protect the prospective Client from overreaching and undue influence employee at the Company or its current employees get! Member of the litigation control group would need to provide their employees with a defense and indemnity the. Provide an attorney with all your information and documents to fully respond your. Martindale-Hubbell accepts no responsibility for the busy in-house practitioner and other readers a rapport before... ( rule 4.2 ) that expressly addresses communications with former employees may not be privileged be privileged with some.... Not displayed Martindale.com and our Frequently asked questions well advised to provide attorney... Expressly addresses communications with former employees under the protection of the attorney-client privilege was employed by SLED as a captain... Deposition notice will toward the Company simultaneously opportunity to talk to former employees under the protection of the attorney-client.! Intended to protect the prospective Client from overreaching and undue influence our Ratings on...