Clinton is resisting producing even a portion of the “after-action” memo, despite an August 22, 2019, ruling by U.S. District Court Judge Royce C. Lamberth that Judicial Watch may ask for the memorandum in its discovery. Clinton refused to produce any part of the memo, alleging that it is fully exempt from disclosure under the “attorney work product doctrine.” In an earlier ruling on a similar issue in this litigation, the Court held that “any contemporaneous documents shedding light on the three narrow discovery topics – even documents evincing attorney impressions, conclusions, opinions, and theories – constitute fact work-product” and should be produced.
Hillary Clinton Resists Court Order to Produce After Action Memo on Search and Review Process that Lead to Deletion of Her Emails; Judicial Watch Files Motion to Compel
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