The following excerpt is from Trust Beneficiaries of SNTL Corp. v. JP Morgan Chase (In re Superior Nat'l Ins. GR.), 518 B.R. 562 (Bankr. C.D. Cal. 2014):
The attorney-client privilege attaches to a confidential communication between the attorney and the client and bars discovery of the communication irrespective of whether it includes unprivileged material. As we explained in Mitchell v. Superior Court, supra, 37 Cal.3d at page 600 [208 Cal.Rptr. 886, 691 P.2d 642] : [T]he privilege covers the transmission of documents which are available to the public, and not merely information in the sole possession of the attorney or client. In this regard, it is the actual fact of the transmission which merits protection, since discovery of the transmission of specific public documents might very well reveal the transmitter's intended strategy.
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