The documents at issue are two versions of a memorandum created by in-house counsel for J-M in the 1980's. In 2003, J-M's litigation counsel discovered the inadvertent disclosure of the unredacted version of the memorandum. In response to correspondence demanding its return, plaintiff's counsel forwarded the document and advised that it had not been disseminated to anyone outside of their firm. Nevertheless, that memorandum, as well as a redacted version of that memorandum...
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