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ey- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
subsequent litigation." 462 U.S. 19, 25, 103 S. Ct. 2209, 76 L. Ed. 2d 387 (1983) (emphasis in original); see also 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 519 n.47 (3d ed. 2010) (collecting cases). Similarly, the work-product doctrine applies regardless of whether litigation actually en
ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot
ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot
ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.I4 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot
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