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This section contains the nature of the case and procedural background.

This is a civil action for damages arising from a contract dispute. Painting (P) sued D for breach of contract. D deposed Nick S. Frangopoulos, and Frangopoulos referred to 24 pages of handwritten notes, prepared earlier at the request of counsel, setting forth the events relevant to this litigation. Frangopoulos examined the notes three times in order to ascertain dates and read from the notes on one occasion. D seeks production of the entire document under Rule 612. P contends that the attorney-client privilege protects the notes from disclosure.

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