In communications between a paralegal and client, the fact that a subject was discussed does not make that subject privileged-as distinguished from the discussion itself.

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Discussions between a paralegal and client are only considered privileged if they relate to legal advice or representation, and the intention is to keep the communication confidential. The fact that a subject was discussed is not enough to make it privileged; it must also meet the criteria of being related to legal advice or representation and intended to be kept confidential.

In Communications Between a Paralegal and Client, the Fact That