Fiduciary Exception Not Applicable to Civil Action against Beneficiary

The fiduciary exception to the attorney-client privilege does not apply to attorney records relating to a civil action brought by a trustee against one of the beneficiaries to enforce an indemnification agreement entered into for a distribution to that beneficiary, and so those records remain subject to attorney-client privilege. In re: First and Partial Account of Gerald L. Hempt, Trustee for the Max C. Hempt QTIP Trust, ___ A.4th ___, 2025 PA Super 2054 (11/13/2025).

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