Court, Explained
U.S. Federal District Courts
←Back to docket
S.D.N.Y.Procedural orderFiled Feb. 27, 2024

Olohan v. Google LLC

Judge
Subramanian
Docket
1:22-cv-10163
Court
U.S. District Court · Southern District of New York
Pages
3
DiscoveryCivil ProcedureEmployment
In one sentence

In Olohan v. Google LLC, Judge Subramanian ordered Tiffany Miller to respond to a discovery motion and submit withheld documents for private court review.

Who this affects

Ryan Olohan and Tiffany Miller, who were involved in a dispute over redacted or withheld communications in the lawsuit.

What happened

In Olohan v. Google LLC, plaintiff Ryan Olohan asked the court to require defendant Tiffany Miller to disclose redacted communications about media coverage of the lawsuit. Miller had withheld the communications based on attorney-client privilege and attorney work-product protection.

Olohan argued that the communications involved media consultants, Miller’s spouse, and lawyers, and concerned responses to media inquiries rather than legal advice or litigation strategy. He also argued that sharing the communications with third parties waived any attorney-client privilege.

Judge Arun Subramanian did not decide the privilege dispute in this order. He ordered Miller to respond to Olohan’s motion by February 29, 2024, and to send the withheld or redacted documents to the court for private review.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Olohan v. Google LLC · No. 1:22-cv-10163
Judge
Subramanian
Date
Feb. 27, 2024

Background

Plaintiff Ryan Olohan submitted a renewed request for a court conference and an order requiring defendant Tiffany Miller to produce unredacted versions of certain communications. The communications involved Miller, media consultants Evan Siegfried and Andrea Calise, Miller’s spouse, and attorneys Aaron Zeisler and Meghan Sullivan. According to Olohan’s submission, the communications concerned media coverage of the lawsuit and responses to related media inquiries, and were created after the complaint was filed.

Miller had redacted or withheld the communications based on attorney-client privilege and attorney work-product protection. Attorney-client privilege generally protects confidential communications made for the purpose of seeking or providing legal advice. The work-product doctrine generally protects certain materials prepared for litigation. Olohan argued that the communications were about public relations and media matters, not legal advice or litigation strategy. He also argued that disclosure to media consultants and Miller’s spouse waived attorney-client privilege and that Miller’s privilege log did not adequately describe at least one communication.

The Court’s Order

The order did not resolve whether the communications were privileged or require their production at that time. Instead, Judge Arun Subramanian ordered Tiffany Miller to respond to Olohan’s motion by February 29, 2024, at 5:00 p.m. By the same deadline, Miller was ordered to email the court unredacted versions of documents she was withholding or redacting for the judge’s private review. The provided text does not include a later ruling on the motion to compel.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
Summary written with AI assistance. See how summaries are made. Spot something wrong? Tell us.