Discussion:
Is an encrypted document definitely a privileged document
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Rob
2011-04-14 23:53:59 UTC
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This question came up recently. If during the discovery of a hard
drive you find damaging evidence in the form of a spreadsheet , adobe
pdf document or word file would that constitute a privileged
document??

What if its in a password protected zip file and you combinatorially
gain access to the file???
n***@isp.com
2011-04-15 21:10:23 UTC
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Is an encrypted document definitely a privileged
document
If by "definitely" you mean to ask whether the fact, without more,
that the document is encrypted evidences that it is privileged, then:
No.

While that a document or other data file (whatever its format when
unencrypted) is encrypted indicates that its creator or other person
who encrypted it wanted to withhold its contents from persons to whom
s/he did not provide an unencrypted copy or decoding information, only
such a desire and intent does not alone support concluding that the
nature of the file or such a file's contents are "privileged" in the
sense that you evidently use that word here.
If during the discovery of a hard drive you find
damaging evidence in the form of a spreadsheet
adobe pdf document or word file would that
constitute a privileged document ??
Whether a document is/isn't "damaging" is a different issue from
whether it is immunized from discovery by reason of it being
privileged or immunized from later use at a trial because it is
privileged.
What if its in a password protected zip file and
you combinatorially gain access to the file ???
How did the you in question get access to the file? Did s/he secret
it away from the owner or other person entitled to its possession? Did
the file's creator or owner say to that you, in substance if not in
these exact words, "You may examine the contents of every file and
examine all other data on this hard disk including, if you find one or
more and if you then so decide, by using some 'brute force' numerical
means or other method of attempting to unencrypt/decode whatever if
any password protected file(s) that may be on the disk" ?

Whether or not there was no such explicit authorization, are there
facts about the communications concerning and other means by which the
you in question learned of the file(s) to which you refer on the basis
of which one ought or at least reasonably may conclude that, even if
the file would have been immune from examination by that you by reason
of some privilege if there were not such communications or other means
of learning of the files,, there has been a waiver of that privilege
in whole or in material part?

In sum, real world answers to your questions will depend on facts you
do not provide in your query.
McGyver
2011-05-03 16:51:28 UTC
Permalink
Post by Rob
This question came up recently. If during the discovery of a hard
drive you find damaging evidence in the form of a spreadsheet , adobe
pdf document or word file would that constitute a privileged
document??
What if its in a password protected zip file and you combinatorially
gain access to the file???
Encryption, password protected zip and your method of access have
nothing to do with whether a document is privileged. A communication
between an attorney and the attorney's client, in either direction, is a
privileged communication (with a few exceptions). A privileged document
remains privileged even if it not encrypted. A communication which does
not qualify as a privileged communication does not become privileged by
encryption, password protection or whatever.

If you will tell us about the document, about the parties and about how
discovery resulted in you having the hard drive, we can advise. If you
are an attorney, here is the proper way to handle the document. Contact
the other side's attorney, describe the document you found, ask whether
it is privileged. If the other attorney says that it is privileged, you
should tell the attorney that you are going to read it and use it unless
he or she takes the matter to a judge with a motion within x days and
obtains a ruling that the document is privileged. Discovery may be
necessary concerning the circumstances of creation of the communication
and it's subsequent handling, so that you can argue in opposition to the
motion that the document is not privileged. If you are not an attorney,
you are not required to follow that procedure.

This answer must not be relied on as legal advice for the reasons posted
here: http://mcgyverdisclaimer.blogspot.com . And I am not your attorney.

McGyver

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