A recent case out of the D.C. Circuit highlights some best practices that can boost the odds that the attorney-client and work product protections will shield internal investigation records. Although not precedential outside the D.C. Circuit, United States ex rel. Barko v. Halliburton is an important victory for the protection of attorney-client communications in internal investigations.  In addition, the District Court below offers helpful advice on how to bolster protection of your internal investigations materials and information.

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