A decision issued on March 6 by the U.S. District Court for the District of Columbia serves as a stark reminder that internal investigations must be carefully structured and executed to garner the protection of the attorney-client privilege and attorney work product doctrine, especially when nonattorneys are being used to assist in the investigation.
In United States ex rel. Barko v. Halliburton, No. 1:05-CV-1276 (D.D.C. slip op. issued March 6, 2014), the court ordered a Halliburton subsidiary to produce documents related to an internal investigation of an alleged Code of Business Conduct violation.
