On Nov. 7, U.S. District Judge for the Middle District of Pennsylvania Malachy E. Mannion issued a decision in Lord v. Napa Management Services, C.A. No. 3:13-2940 (M.D. Pa.). In that decision, Mannion skillfully handled attorney-client privilege and work-product doctrine issues that frequently flummox other courts and litigants.

Napa is a qui tam case where the relator, Lord, contends that the defendants (PMC) engaged in a scheme to defraud Medicare by submitting inflated claims for medical services. Lord sought written discovery from PMC. PMC withheld documents on the basis of both the attorney-client privilege and the work-product doctrine and filed a corresponding motion for a protective order.

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