Limited Liability Corporations combine the characteristics of
corporations and partnerships. Few courts have dealt with the
privilege implications of these hybrid business entities.
In Carpenters Pension Trust v. Lindquist Family LLC,
the court acknowledged that "[t]he application of
attorney-client privilege to members of an LLC is a relatively
uncharted area of law." No. C-13-01063 DMR, 2014 U.S. Dist.
LEXIS 54335, at *8 (N.D. Cal. Apr. 18, 2014). The court ultimately
applied the privilege principles applicable to corporations. After
reviewing withheld documents in camera, the court
concluded that despite the LLC's designation of one person to
be the LLC's "sole manager," several other LLC
members actually "communicated with each other and with the
LLC's attorneys about legal advice relating to the LLC's
business." Id. at *10-11. Because these members acted
as the LLC's day-to-day "managing members,"
"disclosure of confidential information received by one
managing
