‘Peripheral’ Administrative Information About Lawyer’s File Presumptively Privileged

Morris Kaiser's trustee in bankruptcy, Soberman Inc., thought it smelled a rat: while claiming to be impecunious, Kaiser appeared to be living a life of 'some means', which included trips to casinos in the US. Kaiser claimed he was drawing advances on the credit card of a buddy, Cecil Bergman, but the trustee suspected the whole thing was a front to shield Kaiser's assets from his creditors. Soberman applied for the appointment of a receiver over the property of Bergman and his company, on the grounds that their property was actually Kaiser's and should form part of his estate for bankruptcy purposes. The trustee also sought an order for disclosure of the source of all funds Kaiser had received since entering bankruptcy. Kaiser then moved to have the trustee's counsel removed from the record, a motion that was found to be purely tactical. When Kaiser failed to pay the costs of that motion, the judge ordered him to reveal the identity of the party who had been paying