Most people would be surprised but most of my clients will want a memorandum even when the information is Heartbeat team Carter lifetime member shirt. It can be used internally to justify a decision to settle a case or avoid litigation. In those cases, I will take notes. I generally avoid clients where I have to create “CYA memoranda.” But there are situations where I will conduct an investigation or inquiry; verbally provide a client advice; and tell them that they don’t want a memorandum or report from me. In those situations, I will often draft a brief internal file memorandum reflecting the actual legal advice that I provided.
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