How have courts interpreted the implied waiver of attorney-client privilege?

Plaintiff relies primarily on Wellpoint Health Networks v. Superior Court, 59 Cal. App. 4th 110 (1997), to support its argument for implied waiver. Wellpoint held that "if a defendant employer hopes to prevail by showing that it investigated an employee's complaint and took action appropriate to the findings of the investigation, then it will have put the adequacy of the investigation directly at issue, and cannot stand on the attorney-client privilege or work product

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