This is a personal injury action that involved four cars, three cars (C1, C2, C3) were waiting at a stop light one behind another when the fourth car (C4) hit the rear end of C3 forcing a collision with C2 and then forcing C2 to rear end C1. Three insurance companies representing the drivers of C1, C2 and C3 were alleging that the driver of C4 was speeding (40 miles over the posted speed limit) when it collided with C3. The driver of C3 was killed instantly, the driver of C2 was still in the hospital with very serious injuries and the driver of C1 was admitted to the hospital for 2 weeks following this incident. Medical claims for the driver of C2 exceeded $1,000,000. Insurance Company (IC) called a meeting to discuss the case since it was the insurer of the driver of C4. Present at that meeting were in-house counsel for IC, an attorney from an outside law firm that was hired by IC to assist in the litigation, the driver of C4 and two paralegals, one who was employed by IC and one paralegal who was seeking employment with IC and was present at the invitation of IC. The insurance companies for drivers C1, C2 and C3 filed a motion requesting all of the documents presented at that meeting claiming all privileges were destroyed because the second paralegal that was not employed by IC at the time of the meeting. 1. What privileges and confidentiality issues are present in this scenario?

2. Did the second paralegal destroy any and all privileges of the insurer and client (IC and C4) by being present at the meeting? Explain.

3. Does it change your answer if IC hired that second paralegal 3 days after the meeting? Explain