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Illinois federal court clarifies limits of attorney-client privilege questioning

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10

Why it matters

A federal judge in Illinois has clarified when lawyers can refuse to answer deposition questions about attorney-client communications. In Strebel v. Scoular, Case No. 24 C 968, the U.S. District Court for the Northern District of Illinois held that witnesses may be questioned about the fact, timing, location, and general subject matter of privileged discussions, but not about their specific content. The court rejected a defense counsel's blanket instruction to witnesses not to answer foundational questions posed during a deposition break, finding the objections improper though not sanctionable since plaintiffs obtained no meaningful information.

The decision applied federal privilege law rather than Illinois's narrower "control group" standard to resolve the dispute. The court did not impose sanctions despite finding the privilege objections overbroad, reasoning that the improper instructions caused no actual prejudice to the plaintiffs' discovery.

Practitioners litigating in the Northern District of Illinois should note this ruling establishes a workable boundary for privilege disputes in depositions, an area where Illinois state precedent offers limited guidance. The decision is particularly relevant in mixed federal and state-law cases, where federal courts will scrutinize overbroad privilege objections closely and distinguish between permissible foundational inquiries and impermissible probing into the substance of privileged communications.

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