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that "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Ousted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011), the plaintiffs sought to take an interlocutory appeal from an order compelling the testimony of their former attorney

teral order doctrine to appeal from an order compelling it to produce documents which it contended were protected by the attorney-client privilege, the Mohawk Court emphasized that the Court had "stressed that [the Cohen collateral order doctrine] must never be allowed to swallow the general rule that a party is

., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Jury, 705 F.3d 133 (3d Cir. 2012) 9 In re Grand Jury Proceedings, 43 F.3d 966 (5th Cir. 199

of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege.

., 399 F.3d 391, 398 (1st Cir. 2005) 13, 15, 19 Gotham Holdings, LPG. Health Grades, Inc., 580 F.3d 664 (7th Cir. 2009) 15 Holt-Orsted. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 10, 11, 15 In re Grand Jury, 705 F.3d 133 (3d Cir. 2012) 9 In re Grand Jury Proceedings, 43 F.3d 966 (5th Cir. 199

of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege.

es Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 51, 52, 55 In re Air Crash Near Cali, Colombia, 959 F.Supp. 1529 (S.D.F1a. 1997) 38, 40 In re Grand Jury, 705

of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege.

hat "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011), the plaintiffs sought to take an interlocutory appeal from an order compelling the testimony of their former attorne

of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege.

son who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." 4 EFTA00583783 In Holt-Ousted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011), the plaintiffs sought to take an interlocutory appeal from an order compelling the testimony of their former attorney

teral order doctrine to appeal from an order compelling it to produce documents which it contended were protected by the attorney-client privilege, the Mohawk Court emphasized that the Court had "stressed that [the Cohen collateral order doctrine] must never be allowed to swallow the general rule that a party i

hat "when the person who asserts a privilege is a non-litigant," "an appeal from a final judgment [will] be inadequate." In Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011), the plaintiffs sought to take an interlocutory appeal from an order compelling the testimony of their former attorne

of district court litigation and needlessly burden the Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would not lie, the Mohawk Court concluded that 7 EFTA00584609 postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney