McCullough v. Hanley

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION Jack D. McCullough, ) ) Plaintiff, ) ) v. ) No. 17 CV 50116 ) Magistrate Judge Iain Johnston Illinois State Police Agent ) Brion Hanley, et al., ) ) Defendants. ) MEMORANDUM OPINION AND ORDER INTRODUCTION This order addresses the scope of a waiver of the attorney-client privilege under Federal Rule of Evidence 502(a). This order finds that a clumsy invocation and waiver of the attorney-client privilege does not require subject matter waiver of privileged communications when the privilege holder has not and will not…