Moreover, just weeks after St. Simons and RFF were decided, the ABA House of Delegates passed a
resolution urging all «federal, state, tribal, territorial and local legislative, judicial and other governmental bodies» to support applying the attorney - client privilege to protect from disclosure «confidential communications between law firm personnel and their firms» designated in - house counsel made for the purpose of the rendition of professional legal services to the law firm» and to
reject any
claim that conflict of interest principles or the «fiduciary exception» undermine that
claim of privilege.