Through a range of recent US court rulings, companies from Russia, China, the Netherlands and India have had to produce documents because their in-house lawyers have not had a licence. Bank of China was recently required to produce information relating to an internal investigation when the judge involved, Shira Scheindlin, said that lawyer-client privilege was inapplicable.
Unknown in China
Lawyer Laniel Saperstein, who acts for Bank of China, said: 'The notion of US-style discovery is simply unknown in China and other civil law jurisdictions.' Source: ABA
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