RECENT FEDERAL DECISIONS

October 2004

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Illinois Federal District Court Declines to Apply the Self-Critical Analysis Privilege” in Environmental Case
Ludwig v. Pilkington North America, Inc., ___F.Supp.2d___

Ruling that certain documents must be produced during the discovery phase of an environmental dispute, the United States District Court for the Northern District of Illinois has held that, although the self-critical analysis privilege might apply, the documents at issue were not identified with sufficient particularity for the court to find that the privilege applied, even if the privilege were held to exist.