Blurred Lines: Personal Devices, Proportionality, and Piercing the Work Product Privilege

In a fairly short opinion and order, the district court in Weston v. DocuSign, Inc. analyzed whether the parties were entitled to the production of text messages from former employees' personal devices and potential piercing of the attorney work product privilege. Weston is a class action securities fraud case in which Plaintiffs allege that Defendants made misrepresentations regarding the company's projected post-pandemic performance.