In re General Motors LLC Ignition Switch Litigation
United States District Court for the Southern District of New York
80 F. Supp. 3d 521 (2015)
- Written by Sean Carroll, JD
Facts
In response to a discovery of an ignition-switch defect in certain General Motors (GM) (defendant) vehicles, GM conducted an internal investigation. The investigation resulted in a report that GM submitted to the federal government. Several parties (the claimants) (plaintiffs) sued GM for the defect. The plaintiffs issued discovery requests for the report, the GM documents cited in the report, and the notes and memoranda related to witness interviews that underlay the report. GM produced the report and the documents cited in the report but objected to the production of the notes and memoranda, citing the attorney-client privilege, the work-product doctrine, and Federal Rule of Evidence 502 (Rule 502). The claimants argued that GM’s disclosure of the report waived its privileges.
Rule of Law
Issue
Holding and Reasoning (Furman, J.)
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