On June 27, 2014, the D.C. Court of Appeals issued an opinion clarifying that it is not necessary for an investigation to have as only purpose to obtain or provide legal advice in order to maintain privilege. It is sufficient that one of its “significant purposes” was to provide legal advice.
In re Kellogg Brown & Root, Inc., 2014 WL 2895939, No. 1:05-cv-1276 (D.C. Cir. June 27, 2014) can be downloaded at http://www.acc.com… Open PDF