Case on Attorney-Client Privilege in Internal Investigations

The White Collar Crime Prof Blog has an excellent post on a recent Fourth Circuit case on this subject.  Here is their brief summary of the case's focus:

Employees are likely to view the company's lawyer as their own attorney, and corporate counsel has to be careful that the limits of representation are conveyed to the employee without dissuading the person from talking -- corporate cooperation rules the day in the post-Enron world.  An interesting case from the Fourth Circuit, In re: Grand Jury Subpoena (Under Seal) (. . . now that's a catchy title that's easy to distinguish from the 99 other Grand Jury cases), analyzes whether attorneys for AOL who conducted an internal investigation also represented the individual employees.