Extract to table

Risks of Voluntary Production A voluntary-production strategy also carries meaningful risks, which must be carefully managed

The practical upshot of this analysis is clear: because the selective-waiver doctrine is not recognized in the Eleventh Circuit, VHG must not voluntarily produce any materials that are protected by the attorney-client privilege or the work-product doctrine

Within Calderwood & Harkness's document management and production workflows, and within Triton's hosted review platform, all attorney-client communications and work product must be segregated from underlying factual documents

Impact on Ongoing Investigation The internal investigation is in an active phase, and the timing and sequencing of any voluntary production must be carefully calibrated to avoid compromising the investigation's fact-gathering process