Galena St. Fund, LP v. Wells Fargo Bank, N.A., No. 12-cv-00587-BNB-KMT, 2014 WL 943115 (D. Colo. Mar. 10, 2014)

Key Insight: Applying FRE 502, court rejected plaintiff?s argument that defendant waived attorney-client privilege by producing 150 privileged documents among production totaling some 208,000 documents consisting of over 2.2 million pages, as defendant established an elaborate protocol for review and production of documents and took reasonable steps to prevent disclosure of privileged documents, demonstrated that the production was inadvertent, and took reasonable steps to rectify the error with reasonable promptness