Extract to table

Factual and legal positions taken in the PERB defense must be coordinated with the defense of any individual claims to avoid inconsistent positions that could be used to WET's disadvantage

Similarly, the individual claimant's personnel records and employment history may span both the WET and Thornfield periods, potentially creating document production and privilege issues that must be navigated carefully

It cannot be emphasized too strongly that the ethical screen must be rigorously maintained throughout the engagement