The attorney-client privilege protects communications between
clients and their lawyers involving the former's request for
legal advice. Although the privilege can extend to
corporations' collections of internal data, most courts
conclude that business rather than legal concerns motivated such
compilations, and find they are not protected.
On the other hand, some courts take a broad view. In Lopez
v. Longs Drug Stores California, Inc., the court upheld
privilege protection for a six-page document "listing the
names, job titles and employment locations of 139 employees"
being considered for a reduction in force. No. A131638, 2013 Cal.
App. Unpub. LEXIS 3399, at *36 (Cal. Ct. App. May 14, 2013). The
court noted that the Human Resource department prepared the interim
list for lawyers' use, and that only they viewed the list. Nine
days later, another court took a similarly expansive view. In
Church of Christ at Azalea Drive v. Forest River, Inc.,
C.A. No.
