Unless otherwise noted, all statutory citations here shall be to California statutes.
 Compare, for example, Cold Spring Harbor Laboratory v. Ropes & Gray LLP (D. Mass. 2011) 2011 WL 2884893 (firm’s fiduciary duty to client overrides firm’s claim of privilege against client) with TattleTale Alarm Systems, Inc. v. Calfee, Halter & Griswold, LLP, 2011 WL 382627 (S.D.Ohio 2011) (recognizing privilege for the in house communications). See also Hunter, McLean, Exley & Dunn v. St. Simons Waterfront, LLC. 730 S.E.2d 608 (Ga.App.,2012) (rejecting rule of automatic imputation of conflict to result in elimination of privilege, calling it a “Draconian rule”, and analyzing instead the in house counsel’s direct conflict to the outside client, if any)).
 Unless otherwise noted, all rules references are to the California Rules of Professional Conduct.
 There appears to be no authority that disables the privilege as to a law firm’s communications with outside counsel, even if the firm is still representing its outside client. See e.g. SONICblue, supra., 2008 WL 170562 at *11.
 The other 3 categories do not implicate the discussion at issue in this article.
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