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bombcar 4 hours ago

Discovery can even be more broad - "provide all written or recorded messages involving this decision" and if you "forget" about your private diary and it's later found out, that's a paddlin'.

jeffwask 4 hours ago | parent [-]

Absolutely, they can be but your lawyers at least have a leg to stand on to push for exclusion. If they are just sitting next to the PowerPoint you gave on Tuesday, they will definitely be included.