United States of America, ex rel. Rebecca Miller v. Reckitt Benckiser Pharmaceuticals, Inc., n/k/a Indivior Inc.

District Court, W.D. Virginia·Decided September 9, 2026·No. 1:15-cv-00017·Unknown

Opinion

CLERKS OFFICE U.S. DIST. ¢ AT ABINGDON, VA IN THE UNITED STATES DISTRICT COURT mu FOR THE WESTERN DISTRICT OF VIRGINIA | “pemoe: □□ □□□ ABINGDON DIVISION BY: s/ FELICIA CLARK DEPUTY CLERK UNITED STATES OF AMERICA, ef ) al., ex rel. REBECCA MILLER, ) ) Plaintiff-Relator, ) Case No. 1:15CV00017 ) V. ) OPINION AND ORDER ) RECKITT BENCKISER ) JUDGE JAMES P. JONES PHARMACEUTICALS, INC., n/k/a ) INDIVIOR INC., ) ) Defendant. ) Argued: Maghan S. B. Oliver, MOTLEY RICE LLC, Mt. Pleasant, South Carolina, for Plaintiff-Relator; Jonathan T. Blank, MCGuIREWoobDs LLP, Charlottesville, Virginia, for Defendant. Rebecca Miller, the plaintiff-relator in this qui tam action under the False Claims Act and similar local statutes, has moved to compel the production of documents that the defendant Reckitt Benckiser Pharmaceuticals, Inc., now known

as Indivior Inc. (hereafter Indivior) contends are protected by attorney-client and work product privileges. The motion will be granted in part and denied in part. I. BACKGROUND. Plaintiff-Relator Miller engaged independent counsel to review her files and identify material over which Indivior might choose to assert privilege. Independent counsel conducted this review and provided those files to Indivior, with Miller’s potentially privileged information redacted. Indivior reviewed those files and

claimed privilege over portions of 68 of the documents. Miller objects to the assertion of privilege as to 66 of the documents. Miller argues that the crime-fraud exception to attorney-client privilege justifies their disclosure. Further, the parties identified seven documents that independent counsel partially redacted and withheld from both parties on the belief that both might claim

a privilege. Those documents are listed in Exhibit C to Miller’s Motion to Compel. After oral argument, I determined that in camera review of the documents was justified to consider what, if any, of the redacted material could be unredacted and released to the parties. I have reviewed the privilege log and the 66 documents subject to the Motion to Compel, as well as the seven documents withheld from both parties. Based on that review, and consideration of the applicable law, I have determined the privilege status of the documents as described below. Il. STANDARD OF REVIEW. Because this case involves federal causes of action, “[t]he common law — as interpreted by United States courts in the light of reason and experience — governs a claim of privilege.” Fed. R. Evid. 501. A. Attorney-Client Privilege. The attorney-client privilege “affords confidential communications between lawyer and client complete protection from disclosure.” In re Grand Jury Subpoena, 204 F.3d 516, 519 (4th Cir. 2000) (quoting Hawkins v. Stables, 148 F.3d 379, 383

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(4th Cir. 1998)). It “applies only to confidential disclosures by a client to an attorney made in order to obtain legal assistance.” J/d. (internal citations and quotation marks omitted). The attorney-client privilege must be “strictly confined within the narrowest possible limits consistent with the logic of its principle.” Jn re Grand Jury Proceedings, 727 F.2d 1352, 1355 (4th Cir. 1984) (internal quotation marks and citation omitted). “The burden is on the proponent of the attorney-client privilege to demonstrate its applicability.” United States v. Jones, 696 F.2d 1069, 1072 (4th Cir. 1982). B. Work Product Privilege. “[T]he work product doctrine belongs to the attorney and confers a qualified privilege on documents prepared by an attorney in anticipation of litigation.” Solis

v. Food Emp'rs Lab. Relations Ass ’n, 644 F.3d 221, 231 (4th Cir. 2011) (citing, inter alia, Hickman vy. Taylor, 329 U.S. 495, 509-14 (1947)). As with the attorney-client privilege, the burden of showing that the work product protection applies lies with the party asserting the privilege. C. Crime-Fraud Exception. The crime-fraud exception exists “to ensure that the ‘seal of secrecy’ between lawyer and client does not extend to communications made for the purpose of getting advice for the commission of a fraud or crime.” United States v. Regan, 281 F. Supp. 2d 795, 804 (E.D. Va. 2002) (internal citations and quotation marks omitted). For

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the crime-fraud exception to overcome a stated privilege, the party seeking discovery must show that the communications (1) were made for an unlawful purpose or to further an illegal scheme; and (ii) reflect an ongoing or future unlawful or illegal scheme or activity. United States v. Lentz, 419 F. Supp. 2d 820, 831 (E.D. Va. 2005). It does not matter “whether the attorney knew that the client was seeking his advice for illegal purposes” or whether the attorney “counseled against the illegal activity.” Id. at 830. The prima facie showing required to satisfy the crime-fraud exception is proof “such as to subject the opposing party to the risk of non-persuasion if the evidence

as to the disputed fact is left unrebutted.” Jn re Grand Jury 2021 Subpoenas, 87 F.4th 229, 254 (4th Cir. 2023) (internal citation and quotation marks omitted). Here, Miller argues that the crime-fraud exception applies to the challenged documents because the redacted portions of those documents contain information about conversations where Indivior executives conspired with counsel to circumvent reporting requirements. She states that the use of counsel to further a future illegal scheme and the “close relationship” between the conversations and that scheme render the material discoverable.

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II. | DOCUMENTS SUBJECT TO MILLER’S MOTION TO COMPEL. I have reviewed the 66 files over which Miller has challenged Indivior’s privilege to determine whether the crime-fraud exception applies as alleged. Many of the documents are essentially duplicates, although some have slight formatting or wording edits. In any event, many of the redacted sections are consistent among versions of the documents. Therefore, where these sections are consistent, I have grouped together multiple versions of the same document for evaluation. The tables below provide instruction to independent counsel as to which portions of the documents can be unredacted and made available to one or both of the parties. To preserve privilege where applicable, I have included minimal discussion of the contents of the redacted materials. 1. Toxicity: Murder, Mayhem and Debauchery: My Life in the Pharmaceutical Industry. The submitted documents include 14 versions of a manuscript written by Miller that she describes as her “book.” The manuscript reads as a narrative account of Miller’s social and professional interactions, much of which is unrelated to this litigation. In three places where the manuscript discusses Indivior’s operations or decision-making, Indivior has asserted attorney-client privilege.

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United States of America, ex rel. Rebecca Miller v. Reckitt Benckiser Pharmaceuticals, Inc., n/k/a Indivior Inc., (W.D. Va. 2026).

United States of America, ex rel. Rebecca Miller v. Reckitt Benckiser Pharmaceuticals, Inc., n/k/a Indivior Inc. (United States of America, ex rel. Rebecca Miller v. Reckitt Benckiser Pharmaceuticals, Inc., n/k/a Indivior Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Hickman v. Taylor
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148 F.3d 379 (Fourth Circuit, 1998)
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419 F. Supp. 2d 820 (E.D. Virginia, 2005)
United States v. Regan
281 F. Supp. 2d 795 (E.D. Virginia, 2002)
United States v. Jones
696 F.2d 1069 (Fourth Circuit, 1982)
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