Office of the President v. Office of Independent Counsel

How later courts describe this case

• assertion of governmental attorney-client privilege by First Lady in the context of a grand jury investigation
• neither attorney-client privilege nor work product doctrine may be invoked to avoid compliance -with independent prosecutor’s issuance of subpoena to President and First Lady to compel production of documents relating to “Whitewater” investigation
• when common interest doctrine applies, communications among clients to exchange information that relate to the matter are “‘privileged as against third persons. Any such client may invoke the privilege, unless it has been waived by the client who made the communication.’ ”
• parenthetically referencing Branzburg as “rejecting news reporter’s privilege.”