Consumer Class Actions: 9.5.3 Examples of Objectionable Questions Impinging upon the Attorney-Client Privilege
The following are examples of questions that counsel should consider instructing the plaintiff not to answer based on the attorney-client privilege. For some of these questions, the attorney-client privilege is obvious, such as in the following:
[Q.] Were you asked by your lawyer to be a plaintiff in this lawsuit?
[Q.] What is the fee agreement you have with your attorney?