Illinois Supreme Court
Civil Court
Attorney-Client Privilege
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.)