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Protecting Work Product: When the Threat of Litigation Is Too Remote for Privilege

Client Alert | 1 min read | 02.06.20

In Ingham Regional Medical Center v. U.S. (Jan. 6, 2020), the Court of Federal Claims compelled production of certain government investigatory documents that the Court found were not privileged work product prepared “in anticipation of litigation.” The Medical Center sued to recover payments for outpatient healthcare services performed in connection with DoD’s TRICARE program after initial settlement discussions had failed. During discovery, the government inadvertently produced several documents that assessed the accuracy of its previous payments to the Medical Center, including documents that had been repeatedly logged as privileged. Although the government claimed that the documents were prepared in anticipation of litigation, the court held that the documents did not constitute protected work product because they were produced in furtherance of a business purpose (i.e., payment investigation) well before a genuine threat of litigation arose. The court equated the government’s function in assessing the hospital’s claims for alleged underpayments to that of an insurer who investigates a claim before making a final determination. Therefore, since the threat of litigation was too remote, the court found that the work product had been prepared for a possible negotiated business settlement between the parties, rather than for litigation. Contractors and others engaged in litigation with the government should keep “ordinary course of business” arguments in mind as a basis to challenge government privilege assertions.

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Client Alert | 4 min read | 08.21.25

FLSA Overtime Reporting and Withholding

The One Big Beautiful Bill Act (the Act), signed on July 4, 2025, allows a deduction from an individual’s personal tax return on Form 1040 for “qualified overtime compensation” as defined in new Code § 225. The amount that can be deducted from the employee’s return is capped at $12,500 with the maximum then adjusted down if the employee’s AGI exceeds certain limits. This deduction is permitted in 2025....