California, United States of America
The following excerpt is from Proskauer Rose, LLP v. Superior Court of L.A. Cnty., No. B245624 (Cal. App. 2013):
In Lohman v. Superior Court, the court held that a client's disclosure of communications with a former attorney on a subject relevant to her current claims did not waive her privilege to prevent disclosure of her conversations on that same subject with other attorneys. Even assuming the client had waived her privilege as to confidential communications with some of her attorneys, "she did not waive her privilege as to her communications with [another attorney] during his representation of her even though what she told [that attorney] related to the same subject matter or was identical to what she told her prior attorneys. [Citation.]." (81 Cal.App.3d at p. 97.)
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