An implied waiver of privilege can only occur when there is a voluntary disclosure of communication.
2.
Following the rule of indivisibility of waiver, the disclosure of part of a letter pursuant to a general order for discovery constitutes a waiver of privilege in respect of the whole contents of the letter.
3.
The reading out of part of a document by counsel at trial, even without the client's express authority, amounts to a waiver of any privilege attaching to the document as a whole; however, mere reference to a document does not amount to a waiver of privilege.
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