Center Partners, Ltd. v. Growth Head GP, LLC.

Illinois Supreme Court
Civil Court
Citation
Case Number: 
2012 IL 113107
Decision Date: 
November 29, 2012
District: 
1st Dist.
Division/County: 
Cook Co.
Justice: 
GARMAN
Holding: 
Judgments reversed; remanded.
As to privileged attorney-client communications which are disclosed, subject matter waiver does not apply to disclosures made in an extrajudicial context when those disclosures are not thereafter used by the client to gain a tactical advantage in litigation. Deposition testimony of corporate officers did not waive attorney-client privilege so as to allow application of subject matter waiver to certain attorney-client communications. (KILBRIDE, FREEMAN, THOMAS, KARMEIER, BURKE, and THEIS, concurring.)