Manson v. Villafane

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that privilege waived by inadvertent disclosure where “party’s screening effort was manifestly inadequate”
• finding waiver where party failed to take steps to discover other previously overlooked privileged documents divulged after realizing that one privileged document already had been inadvertently disclosed
• “Any order issued now by the court would have only limited effect; it could not force NBNE to forget what has already been learned”
• strict waiver rule “seems too harsh in light of the vast volume of documents disclosed in modern litigation”
• two persons screening large document production over one day period was inadequate for the circumstances
• after learning of a first disclosure of a privileged document, the disclosing party produced another copy of the same document in a document production two days later

Source: CourtListener parenthetical corpus (CC0).