Youngs v. PeaceHealth
Docket Number | 87811-1 |
Decision Date | 23 January 2014 |
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12 cases
- In re Gentry
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Magney v. Pham
...privilege, while others are derogations from the common law, e.g., the physician-patient privilege. See Youngs v. Peacehealth , 179 Wash.2d 645, 650-51, 316 P.3d 1035 (2014) (attorney-client privilege is the oldest common law privilege; legislature enacted physician-patient privilege statut......
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Willeford v. Klepper
...disclosures requires judicial monitoring that cannot occur in the context of ex parte communications"); Youngs v. Peacehealth, 179 Wash.2d 645, 316 P.3d 1035, 1041–43 (2014) (holding that its prior bar on ex parte communications, announced in Loudon v. Mhyre, 110 Wash.2d 675, 756 P.2d 138 (......
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Hermanson v. Multi-Care Health Sys., Inc.
...and the social worker based on corporate attorney-client privilege under Loudon v. Mhyre ,4 Upjohn Co. v. United States ,5 and Youngs v. PeaceHealth .6 Specifically, it argued that its attorney-client privilege allowed ex parte privileged communications with MultiCare’s agents who had fir......
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2 firm's commentaries
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Washington State Supreme Court Limits Attorney-Client Privilege for Healthcare-Provider Corporations
...issue. Republished with permission. This article first appeared in Medical Liability Monitor in May 2014. Todd Presnell Youngs v. Peacehealth, 316 P.3d 1035 (Wash. 2014). BATTLE OF THE PRIVILEGES Washington’s physician-patient privilege statute precludes a physician from revealing her patie......
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Washington State Supreme Court Limits Attorney-Client Privilege For Healthcare-Provider Corporations
...non-party physicians supersedes the corporation's attorney-client privilege with its employed physicians. Youngs v. Peacehealth, 316 P.3d 1035 (Wash. BATTLE OF THE PRIVILEGES Washington's physician-patient privilege statute precludes a physician from revealing her patient's communications, ......
5 books & journal articles
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Table of Cases
...Yates, In re, 90 Wn.2d 767, 585 P.2d 1164 (1978): 8.3(1) Youngs v. Peacehealth, 179 Wn.2d 645, 316 P.3d 1035 (2014): 1.2(4)(a), 9.4(3), 10.3(1), 10.4 Z____________________________________________________________________ Zderic, In re, 92 Wn.2d 777, 600 P.2d 1297 (1979): 8.3(1) WASHINGTON DI......
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§1.2 - Creation of Attorney-Client Relationship
...represents the organization acting through its duly authorized constituents." See also Youngs v. Peacehealth, 179 Wn.2d 645, 677, 316 P.3d 1035 (2014) ("Corporate defense counsel represents the defendant corporation, not its employees.") ("Indeed, counsel cannot corepresent an employer and ......
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§ 3.07 Attorney-Client Privilege and The Work Product Doctrine
...Upjohn Co. v. United States, 449 U.S. 383, 389-90, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981); Youngs v. Peacehealth, 179 Wn.2d 645, 651, 316 P.3d 1035 (2014). Communications with a corporation's in-house counsel are covered in the same way as communications with outside counsel. Upjohn, 499 U......
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§10.3 - The "Who Is The Client?" Question in Specific Organizational Contexts
...in proving later that the lawyer concerned was representing only the entity. See Youngs v. PeaceHealth, 179 Wn.2d 645, 676-77, 316 P.3d 1035 (2014) (Stephens, J., concurring in part and dissenting in part) (describing the role of such warnings under RPC 1.13). It can be equally important as......
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