J-A21033-19
2020 PA Super 42
WAKEEM FORD-BEY, : IN THE SUPERIOR COURT OF ADMINISTRATOR OF THE ESTATE : PENNSYLVANIA OF WANETTA FORD-BEY : : : v. : : : PROFESSIONAL ANESTHESIA : No. 677 EDA 2019 SERVICES OF NORTH AMERICA, : LLC; JOEL D. SOKOLOFF, M.D.; : THOMAS MADDALONI, CRNA; : SCOTT WILSON, CRNA ; PHYSICIANS : CARE SURGICAL HOSPITAL, LP : : : APPEAL OF: THOMAS MADDALONI, : CRNA :
Appeal from the Order Entered January 14, 2019 In the Court of Common Pleas of Montgomery County Civil Division at No(s): No. 2017-02996
BEFORE: BOWES, J., OLSON, J., and FORD ELLIOTT, P.J.E.
OPINION BY BOWES, J.: FILED FEBRUARY 20, 2020
Thomas Maddaloni, CRNA1 appeals from the January 14, 2019 order2
compelling him to produce his handwritten notes that he claims are protected
from disclosure by the attorney-client and work-product privileges. The trial
____________________________________________
1 The designation “CRNA” signifies Certified Registered Nurse Anesthetist.
2 Mr. Maddaloni purports to appeal from the December 12, 2018 order compelling production and overruling claims of privilege. The appeal properly lies from the January 14, 2019 order, which, following reconsideration, re- confirmed the December 12, 2018 order. We have amended the caption accordingly. J-A21033-19
court found that Mr. Maddaloni had not satisfied the four elements necessary
to successfully invoke the attorney-client privilege. Additionally, the court
found that Mr. Maddaloni failed to make the showing necessary for application
of the work-product privilege, i.e., that his notes contained his counsel’s
mental impressions or strategy. After careful review, we affirm.
The facts giving rise to the legal action are as follows. Wanetta Ford-
Bey (“Decedent”) underwent surgery at Physician’s Care Surgical Center
(“Surgical Center”) on June 12, 2015. She died shortly thereafter of
respiratory failure. Wakeem Ford-Bey, the Administrator of Decedent’s estate
(“Administrator”) commenced this medical malpractice action against
Professional Anesthesia Services of North America, LLC, Joel D. Sokoloff, M.D.,
Mr. Maddaloni, Scott Wilson, CRNA, and the Surgical Center on February 13,
2017.
During the course of discovery, a dispute arose that is the subject of the
instant appeal. At Mr. Maddaloni’s discovery deposition, the following
exchange took place:
Q: When you reviewed the chart in preparation for your deposition, did you have it printed out like it is in front of you?
A: Yes.
Q: Okay. Did you take any notes while you were reviewing it?
A: No, I did not.
Q: Did you write anything on your copy of the chart?
A: I believe I did.
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Q: And was that to assist you in your review?
Q: And did you write those notes at home? Or wherever you were reviewing the chart, did you write those notes?
Q: Okay. And where is your copy of the chart?
A: It’s at my home.
Q: If you didn’t have the chart, would you be able to remember the specifics of each and every aspect of the treatment that was provided to Mrs. Ford-Bey on June 12th?
A: No.
Maddaloni Deposition, 2/1/18, at 27-28. Administrator’s counsel asked for a
copy of the annotated record, but Mr. Maddaloni’s counsel objected, asserting
attorney-client and work-product privileges.
On March 5, 2018, Administrator served supplemental interrogatories
and requests for production directed to Mr. Maddaloni for “a copy of the . . .
chart in the possession of [Mr. Maddaloni], which includes all notes, typed or
handwritten, prepared by [him] prior to and in preparation of [his] February
1, 2018 deposition.” Supplemental Interrogatories and Requests for
Production, 3/5/18, at ¶2. The request expressly excluded “references to
mental impressions, conclusions, opinions, memoranda, notes or summaries,
legal research or legal theories of [Mr. Maddaloni]’s attorney and mental
impressions, conclusions or opinions respecting the value or merit of the claim
or defense or respecting strategy or tactics of [Mr. Maddaloni]’s
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representative.” Id. Mr. Maddaloni objected to the request on the ground
that “it seeks information prepared in anticipation of and during the course of
litigation, protected by attorney-client privilege and/or the attorney work
product doctrine, and beyond the bounds of permissible discovery under
Pa.R.C.P. 4003.3.” See Answer to Plaintiff’s Supplemental Interrogatories and
Request for Production of Documents, 8/8/18, at ¶2.
Administrator filed a motion to compel, which Mr. Maddaloni opposed,
and the matter was heard by the discovery master. The trial court, based on
the recommendation of the master, entered an order on December 12, 2018,
directing Mr. Maddaloni to produce the annotated chart within twenty days,
and overruled his objections based on privilege.
Mr. Maddaloni filed a motion for reconsideration, which the trial court
granted. Oral argument took place on January 10, 2019. Counsel for Mr.
Maddaloni represented that his client made the notes “at the direction of or
on the advice of counsel,” but acknowledged that this fact was not in the
record. N.T. Motion for Reconsideration, 1/10/19, at 13-14. When asked by
the court if counsel was relying on “any facts of that nature,” or simply relying
upon the deposition and other record facts, counsel indicated that they were
relying upon the deposition and record. Id. at 14.
Administrator argued that, since there was no evidence that the
handwritten notes were made at counsel’s request, in his presence, or for
purposes of obtaining counsel’s advice, “the attorney-client privilege has not
been made out.” Id. at 23. Mr. Maddaloni offered to provide a supplement if
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the court needed it, but steadfastly maintained that the decision could be
made on the record as it stood because Administrator, the party seeking the
discovery, had not developed a record that would compel production. Id. at
24.
By order of January 14, 2019, the court re-confirmed its December order
directing that the copy of the chart bearing Mr. Maddaloni’s handwritten notes
be produced within seven days of the docketing of the order. Mr. Maddaloni
did not comply. Instead, nine days after the order was docketed, Mr.
Maddaloni filed a motion seeking to supplement the record with his affidavit
dated January 18, 2019. The court denied the motion by order of January 30,
2019.3
Mr. Maddaloni filed a notice of appeal to this Court on February 12,
2019,4 and complied with the court’s order to file a Pa.R.A.P. 1925(b) concise ____________________________________________
3 In the proffered affidavit, Mr. Maddaloni stated that some of the notes were
made while meeting with counsel, others while he reviewed the chart to prepare his defense. Affidavit of Thomas Maddaloni, 1/18/19, at 1. He represented further that all handwritten notes were made with the express intention to communicate information to his attorney for purposes of securing legal assistance, and he did not share the notes with any third persons.
4 Mr. Maddaloni relies upon Pa.R.A.P. 313 and the collateral order doctrine as
the basis for our jurisdiction to entertain this interlocutory appeal. As this Court recently reaffirmed in Farrell v. Regola, 150 A.3d 87, 95 (Pa.Super. 2016), when an appellant asserts that the trial court has ordered him to produce materials that are privileged, we have jurisdiction under Pa.R.A.P. 313(b) (“A collateral order is an order separable from and collateral to the main cause of action where the right involved is too important to be denied review and the question presented is such that if review is postponed until final judgment in the case, the claim will be irreparably lost.”). See also Ben
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statement of errors complained of on appeal. The trial court penned its Rule
1925(a) opinion, and the matter is ripe for our review. Mr. Maddaloni presents
three issues for our review, which we have re-ordered for ease of disposition:
1. Whether the trial court erred and/or abused its discretion in denying [Mr. Maddaloni]’s Motion to Supplement the Record with an Affidavit that [Mr. Maddaloni] offered – which simply memorialized evidence already in the record that established the notes were privileged and protected from discovery pursuant to the attorney-client privilege and work product doctrine - where there would have been no prejudice to plaintiff had the Affidavit been accepted?
2. Whether the trial court erred and/or abused its discretion by ordering [Mr. Maddaloni] to produce handwritten notes, created after commencement of litigation and in preparation for his deposition, where the notes were either written in the presence of [Mr. Maddaloni’s] counsel, or for the purpose of securing legal advice, hence, are protected from discovery by the attorney-client privilege?
3. Whether the trial court erred and/or abused its discretion in directing [Mr. Maddaloni] to produce his handwritten notes, where such notes reflect his counsel’s mental impressions, hence are protected from discovery by the work-product doctrine, as codified by Pennsylvania Rule of Civil Procedure 4003.3, relating to trial preparation material?
Appellant’s brief at 5.
Mr. Maddaloni initially contends that the trial court abused its discretion
in denying his motion to supplement the record with his affidavit. He alleges
that the court imposed “an excessively stringent standard of proof and failed
to properly allow additional substantiation of facts already before the court.”
v. Schwartz, 729 A.2d 547 (Pa. 1999); Yocabet v. UPMC Presbyterian, 119 A.3d 1012, 1016 n.1 (Pa.Super. 2015).
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Appellant’s brief at 28-29. “In view of the importance of the rights involved
and the absence of prejudice to [Administrator],” Mr. Maddaloni maintains
that the court should have permitted him to supplement evidence that already
existed. Id. at 29.
In the trial court’s view, the pleading styled as a motion to supplement
the record was “in substance a second motion for reconsideration.” Trial Court
Opinion, 4/1/19, at 15. Appended thereto was new evidence, i.e., an affidavit
averring new facts that had not been presented before. Citing this Court’s
decisions in Bollard & Assocs., Inc. v. H & R Indus., Inc., 161 A.3d 254,
256 (Pa.Super. 2017), and Kelly v. Siuma, 34 A.3d 86 (Pa.Super. 2011), the
trial court maintained that it was within its discretion to refuse to consider new
evidence presented for the first time in a motion for reconsideration.
Moreover, it reasoned that the facts herein presented an even stronger basis
for refusing to consider new evidence as it was a second request for
reconsideration of the initial discovery order.5 In denying the motion, the
court concluded that, “Under these circumstances, the introduction of new
evidence that could have been presented previously is contrary to any concept
of orderly procedure.” Id. at 16.
5 The trial court acknowledged that the affidavit, if timely offered, would have
been legally sufficient to shift the burden to Administrator to negate the claim of privilege.
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We find no error or abuse of discretion on the part of the trial court. The
trial court granted reconsideration and permitted Mr. Maddaloni to make a
case in support of privilege. At the January 10, 2019 argument, counsel for
Mr. Maddaloni initially advanced an entirely new legal theory in support of
non-disclosure of the notes.6 In support of the applicability of the attorney-
client privilege, however, he was content to rest on the facts established
during his client’s deposition.
Counsel rejected the court’s position that it mattered whether the client
communicated the information with his attorney. He insisted that notes
penned by a client to help him remember information were attorney-client
privileged “either way.” Id. at 8. Thus, counsel argued that it did not matter
whether the notes were made in the presence of counsel since Mr. Maddaloni
testified that he reviewed the Surgical Center chart with his attorney. Id. at
9. In short, Mr. Maddaloni took the position that notes made by a client to
assist the client in preparing for his deposition were attorney-client or work-
product privileged regardless of whether they were communicated to the
attorney. Id. at 11. He argued that the drafters of Rule 4003.3 assumed that
a client’s notes constituted work-product when they specifically extended
protection to the attorney or his investigator. Id. at 5. ____________________________________________
6 Counsel for Mr. Maddaloni asserted that Commonwealth v. Fromal, 195
A.2d 174 (Pa.Super. 1963), prohibited opposing counsel from obtaining a writing which a witness used to refresh his recollection prior to examination where the witness was able to testify from his independent recollection, an argument that he abandons on appeal. See N.T. Motion for Reconsideration, 1/10/19, at 4-5.
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The court asked whether it was “[Counsel’s] position that Mr. Maddaloni
made these notes at the direction of or on the advice of his counsel? Counsel
responded, “It is – I know that to be the case. But having said that, that’s
not in the record before you.” Id. at 13. The court asked for confirmation
that counsel for Mr. Maddaloni was “not relying upon any facts of that nature,”
but relying simply on what is of record from the deposition. Id. at 13-14.
Counsel responded in the affirmative, adding that, “it doesn’t have to be at
the direction of counsel.” Id. at 14.
Administrator countered that there was no evidence of record indicating
that Mr. Maddaloni intended to share those notes with counsel for purposes of
obtaining legal advice. Id. at 16. Finally, Administrator argued that work-
product of the party is discoverable unless it contains the mental impressions
of the attorney or a representative of the party, and that Rule 4003.3 does
not protect the mental impressions of a party.
Generally, we do not allow new evidence to be presented in a motion
for reconsideration, let alone in a second motion seeking to supplement the
record for additional reconsideration. See Kelly, supra, at 94 n.8 (holding
trial court properly refused to consider three affidavits attached to motion for
reconsideration raising new issues and arguments). Nonetheless, as the
foregoing indicates, the trial court granted reconsideration and gave Mr.
Maddaloni a second opportunity to make the requisite showing for application
of the attorney-client and work-product privileges. Mr. Maddaloni’s counsel
first advanced an entirely new legal argument, and then reiterated his prior
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position that the facts elicited in his client’s deposition were sufficient to
support his client’s invocation of privilege. Even after the court reaffirmed its
earlier ruling, Mr. Maddaloni waited until after the court-ordered date for
production before seeking permission to supplement the record with his
affidavit. On these facts, we find the trial court did not abuse its discretion in
refusing to permit Mr. Maddaloni a third opportunity to substantiate the claim
of privilege.
We turn now to the question whether the trial court erred in holding that
Mr. Maddaloni failed to establish that the notes were attorney-client or work-
product privileged.7 The application of the attorney-client privilege and work-
product doctrine are questions of law over which our standard of review is de
novo and our scope of review is plenary. BouSamra v. Excela Health, 210
A.3d 967, 973 (Pa. 2019).
The threshold question before us is whether Mr. Maddaloni properly
invoked the attorney-client privilege. The attorney-client privilege is codified
at 42 Pa.C.S. § 5928. It provides that, unless a client waives the privilege,
an attorney is not competent to testify in a civil case about his client’s
7 The instant appeal does not involve waiver of the attorney-client or work- product privilege, either by failure to assert them or disclosure to improper third persons. The privileges were timely asserted by objection at Mr. Maddaloni’s deposition, and again in opposition to a supplemental motion to compel production. Rather, at issue is whether the party asserting privileges demonstrated facts that justify the application of the claimed privileges. See Law Office of Douglas T. Harris v. Phila. Waterfront Partners, LP, 957 A.2d 1223, 1230 n.8 (Pa.Super. 2008) (and cases cited therein).
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confidential communications to him, and the client cannot be compelled to
disclose those communications. Id. The attorney-client privilege allows
“counsel to provide legal advice based upon the most complete information
from the client.” Yocabet, supra at 1027. As our Supreme Court held in
Gillard v. AIG Ins. Co., 15 A.3d 44 (Pa. 2011), the privilege protects
communications from both lawyers to their clients and clients to their lawyers.
To invoke application of the attorney-client privilege, four elements
must be established:
1) The asserted holder of the privilege is or sought to become a client.
2) The person to whom the communication was made is a member of the bar of a court, or his subordinate.
3) The communication relates to a fact of which the attorney was informed by his client, without the presence of strangers, for the purpose of securing either an opinion of law, legal services or assistance in a legal matter, and not for the purpose of committing a crime or tort.
4) The privilege has been claimed and is not waived by the client.
Yocabet v. UPMC Presbyterian, 119 A.3d 1012, 1027 (Pa.Super. 2015).8
8 The Restatement (Third) of the Law Governing Lawyers § 68, Attorney- Client Privilege, similarly provides that the privilege may be invoked with respect to:
(1) a communication (2) made between privileged persons (3) in confidence (4) for the purpose of obtaining or providing legal assistance for the client.
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Mr. Maddaloni facially invoked the attorney-client privilege at his
deposition and in his responses to requests for production. As the party
asserting the privilege, he “bears the initial burden of producing sufficient facts
to show that [he] has properly invoked the privilege for the communications
that [he] has declined to disclose.” Custom Designs & Mfg. Co. v.
Sherwin-Williams Co., 39 A.3d 372, 379 (Pa.Super. 2012). This often
entails an affidavit, statement, or testimony clarifying the circumstances
under which the communication was made. Id. The trial court must
determine whether the facts support the asserted privilege. See Law Office
of Douglas T. Harris v. Phila. Waterfront Partners, LP, 957 A.2d 1223,
1231 (Pa.Super. 2008) (citing 8 Wigmore, Evidence, § 2322 (McNaughton rev.
1961)); accord Nationwide Mut. Ins. Co. v. Fleming, 924 A.2d 1259,
1265-66 (Pa.Super. 2007) (affirmed by an equally divided court, 924 A.2d
1259 (Pa. 2010); Carbis Walker, LLP v. Hill, Barth & King, LLC, 930 A.2d
573, 581 (Pa.Super. 2007) (explaining that party asserting privilege must
initially set forth facts showing that the privilege has been properly invoked).
If the trial court finds that the party invoking privilege has proffered proof to
satisfy the test, “the burden shifts to the party seeking disclosure to set forth
facts showing that disclosure should be compelled either because the privilege
has been waived or because an exception to the privilege applies.” Id. Absent
a sufficient showing of facts to support the privilege, the burden does not shift
and the communications are not protected.
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Herein, the trial court concluded that Mr. Maddaloni failed to prove that
his notes were communications, i.e., that he communicated them or intended
to communicate them to his attorney. Nor did he demonstrate that his notes
reflected communications from his attorney. Hence, the court found that the
burden did not shift as Mr. Maddaloni had not made the requisite factual
proffer for application of the privilege.
Mr. Maddaloni contends that the trial court’s finding that the notes were
not privileged flies in the face of our decision in Farrell v. Regola, 150 A.3d
87, 95 (Pa.Super. 2016). He cites Farrell for the proposition that a client’s
notes are, ipso facto, attorney-client privileged. The trial court rejected Mr.
Maddaloni’s view of our holding in Farrell, and concluded that Mr. Maddaloni
presented “no evidence – either in response to the Plaintiff’s Motion to Compel
or in support of his Motion for Reconsideration - that his handwritten notes
reflected communications made or to be made by or to his attorney ‘for the
purpose of obtaining or providing professional legal advice.’” Trial Court
Opinion, 4/1/19, at 13 (quoting Gillard, supra at 59).
Mr. Maddaloni misapprehends Farrell. In that case, we held that the
client’s notes taken at both his criminal trial and the civil trial at the direction
of his attorneys and given to the attorneys for their use were attorney-client
privileged. What distinguishes the facts herein from those in Farrell is that
there is no evidence that Mr. Maddaloni’s notes, i.e., the client’s thoughts and
impressions, were “communicated” to counsel or intended for that purpose.
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Mr. Maddaloni stated in his deposition that he wrote notes on his copy
of the chart to assist in his review. See Maddaloni Deposition, 2/1/18, at 27-
28. He did not write the notes, however, while reviewing the chart. Id. He
reviewed the chart at his home, and at the time of his deposition, the
annotated chart was located at his home. Even considering counsel’s
representation at the argument on the motion for reconsideration that the
notes were made “at the direction of or on the advice of counsel,” proof that
the notes were confidential communications between attorney and client, or
related thereto, was absent. See, e.g., In re Investigating Grand Jury of
Philadelphia County No. 88-00-3503, 593 A.2d 402 (Pa. 1991) (holding
that bank president’s handwritten notes taken during a meeting with counsel
reflected confidential communications with counsel and fell within the scope
of the privilege). The record in this case does not reveal whether the notes
written by Mr. Maddaloni were communicated or intended to be communicated
to counsel to secure legal services or assistance, as was the case in Farrell.
Nor does the record indicate that Mr. Maddaloni’s notes reflect counsel’s
communications as in In re Investigating Grand Jury of Philadelphia.
Herein, there is no evidence that Mr. Maddaloni transmitted his notes to
counsel or that the notes reflected counsel’s communications to the client. In
short, there is no evidence that the notes were communicated, which is the
very essence of the attorney-client privilege. See Upjohn Co. v. United
States, 449 U.S. 383, 395-96 (1981) (stating the protection of the attorney-
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client privilege extends only to communications and not to facts). For these
reasons, we find no error or abuse of discretion in the trial court’s holding
that, absent proof that the notes reflected communications between attorney
and client, or that they were intended for that purpose, Mr. Maddaloni failed
to properly invoke the attorney-client privilege.
Nor did Mr. Maddaloni establish that the work-product privilege
protected his notes from disclosure. The work-product privilege, in contrast
to the attorney-client privilege, belongs to the attorney, not the client.
BouSamra, supra at 975. It is codified in Pa.R.C.P. 4003.3, and provides:
Subject to the provisions of Rules 4003.4 and 4003.5, a party may obtain discovery of any matter discoverable under Rule 4003.1 even though prepared in anticipation of litigation or trial by or for another party or for that other party’s representative, including his or her attorney, consultant, surety, indemnitor, insurer or agent. The discovery shall not include disclosure of the mental impressions of a party’s attorney or his or her conclusions, opinions, memoranda, notes or summaries, legal research or legal theories. With respect to the representative of a party other than the party’s attorney, discovery shall not include disclosure of his or her mental impressions, conclusions or opinions respecting the value or merit of a claim or defense or respecting strategy or tactics.
Pa.R.C.P. 4003.3.
As our Supreme Court reaffirmed in BouSamra,
The purpose of the work product doctrine is to protect the mental impressions and processes of an attorney acting on behalf of a client, regardless of whether the work product was prepared in anticipation of litigation. Work product protection provides a privileged area within which an attorney can analyze and prepare a client’s case by enabling attorneys to prepare cases without fear that their work product will be used against their clients.
BouSamra, supra at 976-77 (internal citations and quotations omitted).
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Mr. Maddaloni acknowledges that Rule 4003.3 is silent as to the mental
impressions of a party himself. However, he contends that a party’s notes
after litigation has commenced are likely to reflect his counsel’s mental
impressions. Appellant’s brief at 25. Mr. Maddaloni maintains that clients and
attorneys are not required to parse out what portions of their notes represent
information that will be communicated for purposes of obtaining legal advice
and what portions represent counsel’s advice. Id. Such restrictions, he
claims, would have a “chilling effect on free flow of information between client
and attorney.” Id. He relies upon Hickman v. Taylor, 329 U.S. 495 (1947),
the landmark United States Supreme Court case regarding attorney work-
product protection and argues, without citation to authority, that its rationale
is equally applicable and should be extended to protect the “mental
impressions and trial strategies of the party himself.” Appellant’s brief at 27.
Instantly, the trial court started from the premise that Mr. Maddaloni’s
handwritten notes, even if prepared in anticipation of litigation or trial, were
discoverable if they constituted unprivileged “matter . . . relevant to the
subject matter involved in the pending action.” Pa.R.C.P. 4003.1. Rule
4003.1 expressly provides that any matter, “even though prepared in
anticipation of litigation or trial by . . . another party or by or for that other
party’s representative, including his or her attorney, consultant, surety,
indemnitor, insurer or agent” is discoverable. However, discovery shall not
include disclosure of the mental impressions of a party’s attorney or his
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representative. The issue here was whether Mr. Maddaloni established that
his notes were privileged under Rule 4003.3, i.e., that they reflected the
mental impressions of his attorney or representatives of his attorney.
Mr. Maddaloni simply offered no proof that his notes contained the
mental impressions of his attorney or of his attorney’s representatives. To
the extent his notes, or portions of them, reflected counsel’s advice or
strategy, the notes would be entitled to work-product protection, and perhaps
attorney-client protection. A privilege log is often prepared to parse out which
information is entitled to protection as attorney work-product or attorney-
client communications. In some instances, in camera review is required to
evaluate whether matter is privileged. Herein, Mr. Maddaloni offered no
privilege log or any support for his contention that his notes contained his
counsel’s mental impressions or strategy and constituted attorney work-
product. Moreover, Mr. Maddaloni cites no authority, and we know of none,
supporting his contention that the mental impressions of the client
automatically are protected from disclosure under the attorney work-product
doctrine.
After a thorough review of the record, we find no error of law or abuse
of discretion on the part of the trial court. Mr. Maddaloni failed to timely
satisfy the element requiring proof that his notes were communicated or
intended to be communicated to his attorney, or reflected communications
from his attorney, in order to avail himself of the protection afforded by the
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attorney-client privilege. Furthermore, the record does not establish that his
notes written on a copy of Decedent’s chart during the course of litigation
reflected or contained counsel’s mental impressions and strategies, bringing
them within the scope of protected attorney work-product.
Order affirmed.
Judgment Entered.
Joseph D. Seletyn, Esq. Prothonotary
Date: 2/20/20
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