United States v. MIT

                UNITED STATES COURT OF APPEALS
                    FOR THE FIRST CIRCUIT
                                         

No. 97-1287
No. 97-1382

                  UNITED STATES OF AMERICA,

            Petitioner-Appellee, Cross-Appellant,

                              v.

            MASSACHUSETTS INSTITUTE OF TECHNOLOGY,

            Respondent-Appellant, Cross-Appellee.

                                         

        APPEALS FROM THE UNITED STATES DISTRICT COURT

              FOR THE DISTRICT OF MASSACHUSETTS

      [Hon. George A. O'Toole, Jr., U.S. District Judge]
                                                                   

                                         

                            Before

                    Boudin, Circuit Judge,
                                                     

                 Hill,* Senior Circuit Judge,
                                                        

             and Pollak,** Senior District Judge.
                                                            

                                         

Jeffrey Swope  with whom Matthew P.  Schaeffer and Palmer &  Dodge
                                                                              
LLP were on brief for respondent.
           
Sara S.  Holderness, Tax  Division,  Department  of Justice,  with
                               
whom Loretta C.  Argrett, Assistant Attorney General, Donald K. Stern,
                                                                             
United  States Attorney,  and  Charles  E.  Brookhart,  Tax  Division,
                                                             
Department of Justice, were on brief for petitioner. 

                                         

                      November 25, 1997
                                         
                
                            

*Of the Eleventh Circuit, sitting by designation.

**Of the Eastern District of Pennsylvania, sitting by designation.


     BOUDIN, Circuit Judge.  This case concerns an attempt by
                                      

the  Massachusetts  Institute  of  Technology to  assert  the

attorney-client  privilege   and  work-product   doctrine  in

response  to a  document  request  by  the  Internal  Revenue

Service.  The most important issue presented is whether MIT's

disclosure  of certain of the documents to another government

agency caused it to lose the privilege.  The background facts

are essentially undisputed.

     MIT  is a famous university with tax-exempt status under

26  U.S.C.    501(c)(3).    In  1993,  the IRS  conducted  an

examination of MIT's  records to determine whether  MIT still

qualified for  exempt status and to determine  whether it was

complying with  provisions relating  to employment taxes  and

the reporting of  unrelated business income.  In  aid of this

examination, the IRS requested from MIT copies of the billing

statements of law firms that had represented  MIT and minutes

of  the  MIT  Corporation  and  its  executive  and  auditing

committees.

     In  response, MIT  supplied the documents  requested but

redacted information claimed  to be covered by  the attorney-

client privilege or  the work-product doctrine  or both.   In

mid-1994 the IRS  requested that the redacted  information be

supplied, and MIT declined.  At this point the IRS sought  to

obtain the same documents in unredacted form from the Defense

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Contract  Audit Agency ("the audit agency"), the auditing arm

of the Department of Defense.

     It appears that the same billing statements and possibly

some or all of the minutes sought by the IRS had earlier been

provided  to the audit  agency pursuant to  contracts between

MIT and components  of the Department of Defense.   The audit

agency helps  entities in  the Department  of Defense  review

contract performance  to be sure  that the government  is not

overcharged for services.  Not surprisingly, the audit agency

often reviews the private contractor's books and records.  

     In November 1994, the audit  agency advised the IRS that

it would not turn  over the documents  provided to it by  MIT

without the  latter's consent,  which MIT  declines to  give.

The audit  agency had made  no unconditional promise  to keep

the  documents  secret,  but its  regulations  and  practices

offered  MIT  some   reason  to  think  that   indiscriminate

disclosure   was  unlikely.     The   IRS   then  served   an

administrative  summons  on  MIT  in  December  1994  seeking

specific  unredacted  minutes  of nine  meetings  of  the MIT

Corporation and auditing and executive committees in 1990 and

1991,  and attorneys' billing statements for almost all legal

expenses paid or  incurred by MIT from July  1, 1990, through

June 30, 1991.  26 U.S.C.    7402(b), 7604(a).

     When  MIT  declined to  comply,  the IRS  in  early 1996

petitioned  the district court  to enforce the  summons.  The

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district   court  obtained   briefs,   heard  arguments   and

considered the matter  without an evidentiary hearing  on the

basis of  the declaration filed  by the IRS and  an affidavit

submitted by MIT.  In January 1997, the district court issued

a memorandum  and  order  enforcing  the  IRS  administrative

summons  as to the unredacted  legal bills and the unredacted

versions of most of the minutes sought by the IRS.

     The district court held that the disclosure of the legal

bills  to  the  audit  agency forfeited  the  attorney-client

privilege.  As  to the minutes, the district  court said that

the privilege  remained available because  the government had

not proved that  the minutes had been disclosed  to the audit

agency.   After reviewing  the minutes  in camera,  the court
                                                             

found that  three contained  privileged material  and ordered

MIT to  turn over the  others as unprivileged or  because MIT

had  lost the privilege  by disclosing  the substance  of the

minutes in its now unprivileged legal bills. 

     The  district   court  followed  a   different  path  in

resolving  MIT's work product objection.  The court held that

neither the  legal bills  nor the  minutes were  "prepared in

anticipation of  litigation or for  trial."  Fed. R.  Civ. P.

26(b)(3).  It ruled that  they were therefore discoverable as

ordinary  business records.   Accordingly, the court  did not

discuss  whether  work  product  protection  was   waived  by

disclosure to the audit agency.

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                                         -4-


     MIT  now appeals, arguing that disclosure of the billing

statements  to  the  audit  agency  should  not  forfeit  the

privilege; MIT no  longer claims work product  protection for

the billing  statements.  The  government has  cross-appealed

from the district court's refusal to order production  of the

three remaining minutes;  it says that the burden  was on MIT

to prove that the minutes had not been disclosed to the audit

agency.  MIT responds that  the privilege was not waived even

if the minutes  were disclosed to the audit  agency, and that

the minutes remain protected by the work product doctrine.

     On  an appeal respecting a privilege claim, the standard

of  review depends  on the  issue.   Rulings by  the district

court on  issues of law  are reviewed de novo;  fact findings
                                                         

are  tested under a  clear error standard;  and discretionary

judgments  such as evidentiary rulings are reviewed for abuse

of discretion.   See United  States v. Wilson, 798  F.2d 509,
                                                         

512  (1st Cir.  1986).   On the  principal issue  before us--

forfeiture  by disclosure--this  case goes  about  as far  as

possible in  posing an  abstract issue of  law and  review is

plenary.

     The  question  whether   MIT  forfeited  protection   in

disclosing documents to  the audit agency is  not governed by

any  federal constitutional  provision,  federal statute,  or

rule prescribed by the Supreme Court.  Nor is the enforcement

of  an IRS summons  a matter with respect  to which state law

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supplies a rule  of decision.  Accordingly, the  scope of the

privilege is "governed by the principles of the common law as

they may be interpreted by the courts of the United States in

the light of reason and experience."  Fed. R. Evid. 501.  See
                                                                         

also United States v. Zolin, 491 U.S. 554, 562 (1989).
                                       

     MIT's  Appeal.     We  begin  with  the  attorney-client
                              

privilege.  That privilege has  been familiarly summed up  by

Wigmore in a formula that federal courts have often repeated:

          (1)   Where legal  advice of any  kind is
          sought  (2)  from  a  professional  legal
          adviser in his capacity as such,  (3) the
          communications relating to  that purpose,
          (4) made in confidence (5) by the client,
          (6)  are  at   his  instance  permanently
          protected (7) from  disclosure by himself
          or by the  legal adviser, (8) except  the
          protection be waived.

8 J. Wigmore, Evidence   2292, at 554 (McNaughton rev. 1961).
                                  

The government argues, and the district court agreed, that by

its disclosure to the audit agency, MIT  waived the privilege

to whatever extent that it might otherwise have protected the

billing statements and various of the minutes.

     The  attorney-client privilege  is well-established  and

its  present  rationale  straightforward:    by  safeguarding

communications  between  lawyer  and  client,  it  encourages

disclosures by client to lawyer that better enable the client

to conform his conduct to the requirements of the law and  to

present legitimate claims or defenses when litigation arises.

See Upjohn Co. v. United States, 449 U.S. 383, 389-90 (1981).
                                           

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Waiver  issues aside,  the  contours  of  the  privilege  are

reasonably stable.

     Quite a different  scene presents itself when  one turns

to the problem of "waiver,"  a loose and misleading label for

what is in fact a  collection of different rules addressed to

different  problems.    Cases  under  this  "waiver"  heading

include situations as  divergent as an express  and voluntary

surrender  of   the  privilege,   partial  disclosure   of  a

privileged document, selective  disclosure to some  outsiders

but not  all,  and inadvertent  overhearings or  disclosures.

See McCormick on  Evidence   93, at 341-48  (J.W. Strong ed.,
                                      

4th ed. 1992).

     Even where  the cases are  limited to those  involving a

deliberate   and  voluntary   disclosure   of  a   privileged

communication to someone  other than the attorney  or client,

the case  law is far from settled.   But decisions do tend to

mark  out, although  not with  perfect  consistency, a  small

circle  of   "others"  with  whom information  may  be shared

without   loss   of   the   privilege   (e.g.,   secretaries,
                                                         

interpreters,  counsel  for  a  cooperating  co-defendant,  a

parent present when a child consults a lawyer).1

                    
                                

     1See, e.g., United States v. Bay State Ambulance & Hosp.
                                                                         
Rental Serv., Inc.,  874 F.2d 20, 28 (1st  Cir. 1989); Kevlik
                                                                         
v. Goldstein, 724  F.2d 844, 849 (1st Cir.  1984); Indian Law
                                                                         
Resource Center v.  Department of the Interior, 477  F. Supp.
                                                          
144, 148 (D.D.C. 1979); J. Weinstein & M. Berger, Weinstein's
                                                                         
Federal Evidence    503.08[2], at 503-36 (J.  McLaughlin ed.,
                            
2d ed. 1997).

                             -7-
                                         -7-


     Although the decisions often describe such situations as

ones in which the client  "intended" the disclosure to remain

confidential, see, e.g.,  Kevlik v. Goldstein, 724  F.2d 844,
                                                         

849  (1st Cir. 1984),  the underlying concern  is functional:

that the lawyer be able to  consult with others needed in the

representation  and that  the  client  be  allowed  to  bring

closely  related persons  who are  appropriate,  even if  not

vital, to  a consultation.   Cf. Westinghouse Elec.  Corp. v.
                                                                      

Republic of the  Philippines, 951  F.2d 1414,  1424 (3d  Cir.
                                        

1991).  An  intent to maintain confidentiality  is ordinarily

necessary to continued protection, but it is not sufficient.

     On  the  contrary,  where the  client  chooses  to share

communications  outside this  magic circle,  the  courts have

usually  refused  to  extend the  privilege.2    The familiar

platitude  is that the privilege is narrowly confined because

it hinders the courts in the search for truth.  See Fisher v.
                                                                      

United States, 425 U.S. 391,  403 (1976); 8 Wigmore, supra,  
                                                                      

2291, at 554.   Fairness is also a concern where  a client is

permitted to  choose to  disclose materials  to one  outsider

while  withholding them  from another.    See, e.g.,  Permian
                                                                         

Corp. v. United States, 665 F.2d 1214, 1221 (D.C. Cir. 1981).
                                  

                    
                                

     2In addition to the cases cited  in note 3 below, see In
                                                                         
re Grand Jury Proceedings, 78  F.3d 251, 254 (6th Cir. 1996);
                                     
United States v. Jones, 696  F.2d 1069, 1072 (4th Cir. 1982);
                                  
In re Sealed Case, 676 F.2d 793,  818 (D.C. Cir. 1982); In re
                                                                         
Horowitz, 482 F.2d  72, 81 (2d Cir.), cert.  denied, 414 U.S.
                                                               
867 (1973); McCormick on Evidence, supra,   93, at 347-48.
                                                    

                             -8-
                                         -8-


     Should  this  inclination  not  to  protect  a  document

disclosed  outside the  circle  apply  where,  as  here,  the

initial disclosure was to and  at the request of a government

agency?  This  problem has presented itself  to six circuits.

The  most common  cases have  been  disclosures of  otherwise

privileged attorney-client  communications to  the Securities

and  Exchange  Commission  by corporations  during  voluntary

internal investigations or in response to SEC subpoenas.  The

Eighth Circuit, en banc but  without more than a paragraph of
                                   

analysis, treated this kind of disclosure as not comprising a

total waiver of the privilege.   See Diversified Indus., Inc.
                                                                         

v. Meredith,  572 F.2d  596, 611 (8th  Cir. 1978)  (en banc).
                       

Subsequently,  the Second,  Third, Fourth,  Federal  and D.C.

Circuits  took the opposite view and  ruled that such limited

disclosures do destroy the privilege.3

     The  primary argument  in favor  of  the Eighth  Circuit

position  is that  loss of  the privilege may  discourage the

frank exchange between  attorney and client in  future cases,

wherever the  client anticipates  making a  disclosure to  at

least one government agency.  We put to one side the interest

of the government agency  in obtaining voluntary disclosures;

                    
                                

     3See Genentech,  Inc. v. United States  Internat'l Trade
                                                                         
Comm'n,  122  F.3d  1409,  1417  (Fed.  Cir.  1997);   In  re
                                                                         
Steinhardt  Partners, L.P., 9  F.3d 230, 235  (2d Cir. 1993);
                                      
Westinghouse,  951 F.2d  at 1424-26;  In  re Martin  Marietta
                                                                         
Corp., 856  F.2d 619, 623-24  (4th Cir. 1988),  cert. denied,
                                                                        
490 U.S. 1011 (1989); Permian, 665 F.2d at 1220-21.
                                         

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                                         -9-


such  agencies usually have  means to secure  the information

they need  and, if not,  can seek legislation  from Congress.

By  contrast,   the  safeguarding   of  the   attorney-client

relationship has largely been left  to the courts, which have

a comparative  advantage in  assessing  consequences in  this

sphere.

     But MIT, like any client, continues to  control both the

nature  of its communications  with counsel and  the ultimate

decision  whether  to disclose  such communications  to third

parties.  The only constraint imposed by the traditional rule

here  invoked by the  government--that disclosure to  a third

party waives the privilege--is to limit selective disclosure,
                                                             

that is, the provision of otherwise privileged communications

to one outsider while withholding them from another.  MIT has

provided  no evidence  that respecting  this constraint  will

prevent it or anyone else from getting adequate legal advice.

     Admittedly, the arguments on the other side are far from

overwhelming.   The IRS'  search for truth  will not  be much

advanced if MIT  simply limits or recasts its  disclosures to

the audit agency.  But  the general principle that disclosure

normally  negates the  privilege is  worth  maintaining.   To

maintain it here makes the law more predictable and certainly

eases  its  administration.   Following the  Eighth Circuit's

approach  would require,  at the  very  least, a  new set  of

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difficult line-drawing exercises that  would consume time and

increase uncertainty.

     MIT says that even if we are not  prepared to follow the

Eighth Circuit onto new ground, MIT's disclosure to the audit

agency  should be  regarded as  akin to  the disclosure  by a

client's lawyer to another lawyer representing another client

engaged in a common defense.  Invoking the concept of "common

interest," MIT  seeks to compare its situation to cases where

disclosure   has   been  allowed,   without   forfeiting  the

privilege, among separate parties similarly aligned in a case

or  consultation (e.g.,  codefendants,  insurer and  insured,
                                  

patentee and licensee).4

     In a rather abstract sense,  MIT and the audit agency do

have  a "common interest" in the  proper performance of MIT's

defense  contracts and  the proper  auditing  and payment  of

MIT's bills.  But this is not the kind of common  interest to

which the  cases refer in recognizing that allied lawyers and

clients--who are working together in prosecuting or defending

a   lawsuit  or  in  certain  other  legal  transactions--can

exchange  information among  themselves without  loss  of the

                    
                                

     4Compare In re  Regents of Univ. of Cal.  101 F.3d 1386,
                                                         
1390-91  (Fed. Cir.  1996),  cert. denied,  117  S. Ct.  1484
                                                     
(1997), and Hewlett-Packard  Co. v. Bausch &  Lomb, Inc., 115
                                                                    
F.R.D.  308,  310 (N.D.  Cal. 1987),  and Roberts  v. Carrier
                                                                         
Corp., 107  F.R.D. 678, 687-88  (N.D. Ind. 1985), with  In re
                                                                         
Grand  Jury Subpoena Duces  Tecum, 112 F.3d  910, 922-23 (8th
                                             
Cir.), cert.  denied,  117  S. Ct.  2482  (1997),  and  Linde
                                                                         
Thomson Langworthy Kohn & Van Dyke, P.C., v. Resolution Trust
                                                                         
Corp., 5 F.3d 1508, 1515 (D.C. Cir. 1993).
                 

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privilege.  To  extend the notion to MIT's  relationship with

the   audit  agency,  which   on  another  level   is  easily

characterized  as  adversarial,  would  be  to  dissolve  the

boundary almost entirely.

     MIT  further argues  that the  disclosure  to the  audit

agency was not "voluntary" because of the practical pressures

and  the legal  constraints  to  which it  was  subject as  a

government contractor.   The  extent of  those pressures  and

constraints  is far from  clear,5 but assuming  arguendo that
                                                                    

they existed, MIT  chose to place itself in  this position by

becoming a government contractor.  In short, MIT's disclosure

to the  audit agency resulted from its  own voluntary choice,

even if that choice was made at the time it became  a defense

contractor  and subjected itself to the alleged obligation of

disclosure.  See In re John Doe  Corp., 675 F.2d 482, 489 (2d
                                                  

Cir. 1982).

     Anyone  who chooses to disclose a privileged document to

a third  party, or does so  pursuant to a  prior agreement or

understanding, has an incentive to do so, whether for gain or

to avoid  disadvantage.   It would  be perfectly  possible to

carve out some  of those disclosures  and say that,  although

the  disclosure itself is  not necessary to  foster attorney-

                    
                                

     5MIT's main citation for its  duty to disclose is not to
a statute or regulation but to a procedures manual maintained
by  the audit agency.   There is no  actual evidence that MIT
would have been denied payment  if it had sought to negotiate
some lesser disclosure.

                             -12-
                                         -12-


client communications, neither does it forfeit the privilege.

With rare  exceptions, courts  have been  unwilling to  start

down this path--which has no logical terminus--and we join in

this reluctance.

     We add, finally, a word about reliance and fair warning.

MIT  may have had some reason  to think that the audit agency

would not disclose  the documents to the IRS  (and the agency

did not do so).  But MIT had far less reason to think that it

could  disclose documents  to  the  audit  agency  and  still

maintain   the  privilege  when  IRS  then  sought  the  same

documents.  See  note 3, above.   The choice to disclose  may
                           

have been reasonable but it was still a foreseeable gamble.

     The IRS Appeal.  We  turn now to the government's cross-
                               

appeal.   Here,  the  IRS  challenges  the  district  court's

refusal to  require MIT  to produce  three specific  minutes.

The  refusal reflected  the district  court's  view that  the

documents  contained privileged material,  and that there was

no waiver  because MIT had  not been shown to  have disclosed

those minutes to the audit agency.   On the latter point, MIT

effectively concedes error, and properly so.

     Where  privilege is claimed  and the opponent  alleges a

specific disclosure, the burden of proof is upon the claimant

to  show nondisclosure  wherever  that  is  material  to  the

disposition of the  claim.  Cf. United States  v. Wilson, 798
                                                                    

F.2d 509, 512-13 (1st Cir. 1986).  Here, MIT concedes that it

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cannot  prove that the minutes in question were withheld from

the audit agency.   Instead, it proffers  alternative grounds

for  sustaining the  district court's  judgment  as to  these

minutes,  namely, that the  minutes were protected  under the

attorney-client privilege and  the work product  doctrine and

that  these protections  were  not  waived  even  though  the

minutes were turned over to the audit agency. 

     A  party may  defend  a  judgment in  its  favor on  any

legitimate ground without appealing from the judgment on that

issue.   Martin v.  Tango's Restaurant, Inc.,  969 F.2d 1319,
                                                        

1325  (1st  Cir.  1992).    Our  discussion  of  the  billing

statements  disposes of MIT's argument that the protection of

the  attorney-client  privilege  survived disclosure  to  the

audit  agency.    We  therefore  turn  to  the  work  product

doctrine.  In doing so, we reject the government's claim that

MIT waived this  work product argument by only  raising it in

its  reply brief;  MIT's "reply"  brief  was effectively  its

answering brief  on the  government's cross  appeal, and  the

government filed its own "reply" in turn.

     The district  court assumed that work product protection

did  not  apply because  the  minutes were  not  prepared "in

anticipation of litigation,"  as required by Fed.  R. Civ. P.

26(b)(3).   MIT argues that the minutes contained substantive

information  that did represent attorney work product even if

the minutes had a more general function.  There is little law

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in  this area--partly,  one  suspects,  because work  product

usually remains embodied in documents unquestionably prepared

for  litigation  or, if  given  to the  client,  in documents

independently protected by the attorney client privilege.  

     The  government has chosen in its  brief to assume that,

to   the  extent  that  the  minutes  contained  "the  mental

impressions,  conclusions, opinions,  or  legal theories"  of

MIT's attorneys,   Fed.  R. Civ.  P.  26(b)(3), the  district

court   erred  in  concluding  that  work  product  lost  its

protection when repeated in another confidential document not

prepared  in anticipation  of litigation.    A Third  Circuit

precedent supports this assumption, which MIT presses and the

government does not resist.   See In re  Ford Motor Co.,  110
                                                                   

F.3d  954, 967 (3d  Cir. 1997).  In  view of the government's

concession, we will take the  point as settled for this case.

     Nevertheless,  the  government  claims  that  any   such

protection was lost when the  minutes were turned over to the

audit agency, MIT  having conceded that it cannot  prove that

the minutes were not so disclosed.  One might wonder  why the

standard of  waiver for  the attorney-client  privilege--that

any voluntary disclosure outside the magic circle constitutes

waiver--would  not also apply  to the work  product doctrine.

Equivalent waiver standards would make easier  the resolution

                             -15-
                                         -15-


of  evidentiary disputes  where, as  often  happens, the  two

objections are raised together.  

     Nonetheless, the cases  approach uniformity in  implying

that work-product protection  is not as easily  waived as the

attorney-client privilege.   The  privilege, it  is said,  is

designed to protect confidentiality,  so that any  disclosure

outside  the magic circle is inconsistent with the privilege;

by  contrast, work  product  protection  is provided  against

"adversaries,"  so  only   disclosing  material   in  a   way

inconsistent  with keeping it  from an adversary  waives work

product protection.  At least five circuits have adopted this

rule  in some form.6   See also 8  C. Wright, A.  Miller & R.
                                           

Marcus,  Federal Practice  and Procedure     2024, at  368-69
                                                    

(1994) (citing cases).

     Perhaps such formulations  simply beg the question.   If

one  wanted to explain  the discrepant outcomes,  it might be

more  persuasive  to  say  that  the  privilege  is  strictly

confined  because  it is  absolute; on  the other  hand, work

product  protection  (with  certain  qualifications)  can  be

overcome by  a sufficient showing of need.   See Fed. R. Civ.
                                                            

P. 26(b)(3).  In all events, it would take better reason than

                    
                                

     6See  Westinghouse,  951  F.2d  at  1428-29;  Steinhardt
                                                                         
Partners, 9 F.3d at 234-35;  In re Subpoenas Duces Tecum, 738
                                                                    
F.2d 1367, 1371-75  (D.C. Cir. 1984); Martin  Marietta Corp.,
                                                                        
856 F.2d  at  625;  In re  Chrysler  Motors  Corp.  Overnight
                                                                         
Evaluation Program  Litig., 860  F.2d 844,  846-47 (8th  Cir.
                                      
1988).

                             -16-
                                         -16-


we have to depart from the prevailing rule that disclosure to

an  adversary,  real  or  potential,  forfeits  work  product

protection.

     MIT's disclosure to the audit agency was a disclosure to

a potential adversary.  The disclosures did not take place in

the context of a joint  litigation where the parties shared a

common legal interest.  The audit agency  was reviewing MIT's

expense submissions.  MIT doubtless hoped that there would be

no  actual controversy  between  it  and  the  Department  of

Defense,  but the potential  for dispute and  even litigation

was certainly there.   The cases treat this  situation as one

in which the work product protection is deemed forfeit.  See,
                                                                         

e.g., Steinhardt Partners,  9 F.3d at 234;  Westinghouse, 951
                                                                    

F.2d at  1428-31; In  re Subpoenas Duces  Tecum, 738  F.2d at
                                                           

1372 (D.C. Cir. 1984).

     In  closing,  it  may be  helpful  to  stress that--with

regard to  both the  attorney-client privilege  and the  work

product doctrin
                      ine--we are concerned only with loss of  protection

as to  the  very documents  already  disclosed to  the  audit

agency.  Nothing  in this opinion is intended  to be directed

to  the different and  difficult question when  disclosure of

one  document   warrants  forfeiture  of  protection   for  a

different but related document.  That issue was touched on in

the district court but has not been pursued on appeal.

                             -17-
                                         -17-


     Similarly, even  where work  product can  be discovered,

the  governing rule  directs that  "the  court shall  protect

against disclosure  of the  mental impressions,  conclusions,

opinions,  or  legal   theories  of  an  attorney   or  other

representative of a  party concerning the litigation."   Fed.

R.   Civ.  P.  26(b)(3).    Conceivably,  the  strong  policy

underlying  this  reservation  might serve  to  protect  such

materials,  even  if  protection  of  ordinary  work  product

materials were deemed waived because of selective disclosure.

This possibility has not been briefed or argued to us; it may

or may not  be pertinent in this case; and we mention it only

to stress that we are not deciding the issue.

     Accordingly,  on  MIT's  appeal,  the  judgment  of  the

district  court  is  affirmed.   On  the  government's cross-
                                         

appeal, the judgment  of the district court refusing to order

production of  three specified  minutes is  vacated, and  the
                                                               

matter   is  remanded  to  the  district  court  for  further
                                 

proceedings consistent with this opinion.

     It is so ordered.
                                 

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