Client is being sued for securities fraud. The plaintiff alleges that Client lied to the public about Corporation’s financial status to inflate the stock price. In a confidential meeting at

Client is being sued for securities fraud. The plaintiff alleges that Client lied to the public about
Corporation’s financial status to inflate the stock price. In a confidential meeting at Attorney’s
office, Client tells Attorney about an incriminating memo she sent to other officers of
Corporation about Corporation’s financial statements, and provides Attorney with a copy.
Attorney then receives a request for the production of all memoranda relating to the
Corporation’s financial statements. Attorney should:
a-Produce the memorandum
b-Withhold the memorandum on the basis of attorney-client privilege, and put a proper entry on a privilege log notifying plaintiff of the withholding
c- Withhold the memorandum on the basis of work product doctrine, and put a proper entry on a privilege log notifying plaintiff of the withholding
d- Withhold the memorandum, if it would not be admissible at trial

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