CourtAlert.com, Inc. v. American LegalNet, Inc.
- Vernon Broderick
- 1:20-cv-07739
- U.S. District Court · Southern District of New York
- 2
In CourtAlert.com v. American LegalNet, Magistrate Judge Figueredo ruled which parts of nine documents were privileged and which had to be produced.
CourtAlert.com, Inc., American LegalNet, Inc., Mr. Loeb, and the other persons or entities involved in the nine reviewed documents were affected by the rulings on what information could be withheld, redacted, or produced.
What happened
CourtAlert.com, Inc. v. American LegalNet, Inc. involved Plaintiff’s request for the Court to review nine documents that Defendants claimed were protected by attorney-client privilege.
The Court found that the retainer letter was not privileged. It found that the other eight documents contained a mixture of privileged and nonprivileged material: some portions could be redacted, while other portions had to be produced, including several emails and two documents that were not privileged in full. One email chain was found to be entirely privileged.
Magistrate Judge Valerie Figueredo issued the ruling on May 23, 2025, resolving the document-privilege dispute identified at ECF No. 99.
The detailed version
- CourtAlert.com, Inc. v. American LegalNet, Inc. · No. 1:20-cv-07739
- Vernon Broderick
- May 23, 2025
Background
At Plaintiff’s request, the Court conducted a private review of nine documents that Defendants claimed were protected by the attorney-client privilege. The documents concerned the relationship between attorney David Shapiro, American LegalNet, Inc. (ALN), and Mr. Loeb, including a potential dispute with CourtAlert concerning Mr. Loeb’s resignation and subsequent move to ALN.
Rulings on the Documents
The document beginning with ALN03490, a retainer letter, was not privileged. The Court stated that the letter established an attorney-client relationship between Mr. Shapiro, ALN, and Mr. Loeb.
The other eight documents contained both privileged and nonprivileged material. The Court explained that some portions were not privileged because they did not involve an attorney, confidential information, or legal advice from an attorney. In particular, the email chain beginning at ALN02285 was not wholly privileged. The top email from June 10, 2020, at 10:10 a.m. contained one privileged statement that could be redacted, but the remainder of the chain was not privileged and did not disclose attorney communications or legal advice.
The Court’s specific rulings, identified by the first Bates number in each document range, were:
- ALNO2350: The last email in the chain between Mr. Loeb and Yaniv Schiller was not privileged and was to be produced without redaction. The same email appearing in the other identified documents was also to be produced without redaction. The remainder of the email communications in this document was to be redacted. - ALNO02289, ALNO2342, and ALNO2358: All communications in each email chain could be redacted except for the email from Mr. Loeb to Yaniv Schiller. - ALNO5951: All emails in the chain were privileged. - ALNO2292: The email was not privileged and was to be produced. - ALNO03600: The document was not privileged and was to be produced.
Disposition
The order resolved the dispute at ECF No. 99. It addressed discovery and attorney-client privilege rather than deciding the parties’ underlying dispute concerning Mr. Loeb’s resignation and move to ALN.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.