Castillo v. The Well Community Church

District Court, E.D. California·Decided June 22, 2023·No. 1:21-cv-01460·Unknown

Opinion

KRYSTAL CASTILLO, No. 1:21-cv-01460-ADA-BAM

Plaintiff, ORDER AFTER IN CAMERA REVIEW v. THE WELL COMMUNITY CHURCH, a California corporation, Defendant.

In this case, Plaintiff Krystal Castillo (“Plaintiff”) alleges employment discrimination, retaliation, interference with prospective economic relations, and defamation by Defendant The Well Community Church (“Defendant”). (Doc. 39.) In response to Plaintiff’s Requests for Production No. 47-49 and 53, Defendant produced responsive documents but also withheld or redacted approximately 20-25 emails that it claimed were protected by attorney-client privilege or work product doctrine. (Doc. 55.) To resolve the remaining issues regarding whether these documents were privileged, the Court directed Defendant to submit the identified emails and any other similar emails located during Defendant's rolling production which do not have an attorney as sender or recipient that are alleged to be privileged to the Court for in camera review. (Id.) The Necessity for In Camera Review As it pertains to the in camera review, Defendant noted that all “responsive non-privileged documents have been provided to Castillo in response to Requests for Production requests numbered 47-49 and 53, arising out of the email search terms requested by plaintiff.” (Doc. 57 at 1.) However, Defendant withheld documents under privilege that were “attorney communications, management discussions of attorney communications, and work product prepared in anticipation of litigation.” (Id.) Plaintiff maintained that Defendant’s privilege log was overly broad and that Defendant bore the burden of showing that the attorney-client privilege or work product doctrine applied. (Doc. 49 at 2, Doc. 53 at 1, Doc. 56 at 1.) The Court ordered Defendant to submit the identified 20-25 emails and any other similar emails located during Defendant’s rolling production which do not have an attorney as sender or recipient that are alleged to be privileged to the Court for in camera review. (Doc. 55.) This Order is entered after considering the 21 exhibits submitted by Defendant and conducting an in camera review. Description of Documents Submitted for In Camera Review On May 30, 2023, the Court received documents from Defendant submitted for in camera review, which consist of 21 exhibits containing email discussions between Defendant’s employees or between Defendant’s employees and counsel. Each exhibit will be addressed in turn below. Legal Standard “A district court may conduct an in camera inspection of alleged confidential communications to determine whether the attorney-client privilege applies.” Clarke v. Am. Com. Nat. Bank, 974 F.2d 127, 129 (9th Cir. 1992). Attorney-client privilege applies “(1) [w]here legal advice of any kind is sought (2) from a professional legal adviser in his capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or by the legal adviser, (8) unless the protection be waived.” In re Grand Jury Investigation, 974 F.2d 1068, 1071 n. 2 (9th Cir.1992) (quoting Matter of Fischel, 557 F.2d 209, 211 (9th Cir. 1977)). “Because it impedes full and free discovery of the truth, the attorney-client privilege is strictly construed.” United States v. Martin, 278 F.3d 988, 999 (9th Cir. 2002) (quoting Weil v. Inv./Indicators, Rsch. & Mgmt., Inc., 647 F.2d 18, 24 (9th Cir. 1981). Attorney-client privilege “may attach to communications between nonlegal employees where: (1) the employees discuss or transmit legal advice given by counsel; and (2) an employee discusses her intent to seek legal advice about a particular issue.” Datel Holdings Ltd. v. Microsoft Corp., No. C-09-05535 EDL, 2011 WL 866993, at *5 (N.D. Cal. Mar. 11, 2011) (quoting U.S. v. ChevronTexaco Corp., 241 F. Supp. 2d. 1065, 1077 (N.D. Cal. 2002)) (internal quotation marks omitted); see also AT & T Corp. v. Microsoft Corp., No. 02-cv-0164 MHP (JL), 2003 WL 21212614, at *3 (N.D. Cal. Apr. 18, 2003) (“Communications between non-lawyer employees about matters which the parties intend to seek legal advice are likewise cloaked by attorney-client privilege.”). In applying this privilege, courts have required sufficiently detailed declarations to demonstrate that the communications at issue were actually connected to the employees’ intent to seek legal advice or upon attorneys’ instructions/direction of employees’ actions. See Datel, 2011 WL 866993, at *6 (Lange, the person who drafted the allegedly privileged email, “had participated in a conference call with Shelley McKinley, Microsoft's in-house counsel, on that morning concerning Microsoft's potential infringement claims against Datel… McKinley requested on that call that Lange conduct an investigation into the potential claims and enlist other employees with relevant technical expertise.”); U.S. ex rel. Schmuckley v. Rite Aid Corp., No. 2:12-CV-01699 KJM JDP, 2023 WL 425841, at *3 (E.D. Cal. Jan. 26, 2023) (finding emails from internal auditor conducting investigation at request of attorney to be privileged). Here, declarations from Defendant about the communications which were privileged are unnecessary because the actual emails were provided to the Court for review. Furthermore, courts have tailored the privilege specifically to the portion of documents in which the attorney’s advice is conveyed or discussed. See Datel, 2011 WL 866993, at *6 (“the only portion of the ‘Re-auth’ email chain that is protected by the attorney- client privilege is the original email from [the person who conveyed the attorney’s request for an investigation into an issue]”). A district court may also review documents to determine whether work product protections apply. See, e.g., Lopes v. Vieira, 719 F. Supp. 2d 1199 (E.D. Cal. 2010) (District Court determining that documents submitted for in camera review were protected by work product doctrine). “The work product doctrine, codified in Federal Rule of Civil Procedure 26(b)(3), protects ‘from discovery documents and tangible things prepared by a party or his representative in anticipation of litigation.’” In re Grand Jury Subpoena (Mark Torf/Torf Env't Mgmt.), 357 F.3d 900, 906 (9th Cir. 2004) (quoting Admiral Ins. Co. v. United States District Court, 881 F.2d 1486, 1494 (9th Cir.1989)). The Ninth Circuit has held that “to qualify for protection against discovery under [Rule 26(b)(3)], documents must have two characteristics: (1) they must be ‘prepared in anticipation of litigation or for trial,’ and (2) they must be prepared ‘by or for another party or by or for that other party's representative.’” Id at 907 (quoting In re California Pub. Utils. Comm’n, 892 F.2d 778, 780–81 (9th Cir.1989)). However, the “work product doctrine does not protect materials assembled in the ordinary course of business.” Griffith v. Davis, 161 F.R.D. 687, 698 (C.D. Cal. 1995). “Rather, the primary motivating purpose behind the creation of the materials must be as an aid in possible future litigatio

Free access — add to your briefcase to read the full text and ask questions with AI

Castillo v. The Well Community Church, (E.D. Cal. 2023).

Castillo v. The Well Community Church (Castillo v. The Well Community Church) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lopes v. Vieira
719 F. Supp. 2d 1199 (E.D. California, 2010)
Anderson v. Marsh
312 F.R.D. 584 (E.D. California, 2015)
Griffith v. Davis
161 F.R.D. 687 (C.D. California, 1995)