NAL but generally familiar with law. Medical (and especially therapy) notes, attorney/client communications, and a few other have privilege [1] and you would n

NAL but generally familiar with law. Medical (and especially therapy) notes, attorney/client communications, and a few other have privilege [1] and you would not /required/ to submit this. If the opposing side requested something that turned them up, and they were responsive, you'd include a response and include a reference in a "privilege log" [0] What is privileged is subtle and often overstated. You can't just put "attorney/client privilege" and CC a lawyer — you need to be asking a genuine legal question. Google almost got in trouble for something like this [2]. Private notes, including diaries, are not privileged. I'd like to see some serious proposals for "diary privilege" but no state has such a rule. [0] https://www.jdsupra.com/legalnews/creating-privilege-logs-a-best-2761084/ https://www.jdsupra.com/legalnews/creating-privilege-logs-a-... [1] https://www.law.cornell.edu/wex/privileged_communication https://www.law.cornell.edu/wex/privileged_communication [2] https://www.proskauer.com/blog/the-sound-of-silent-attorneys-doj-alleges-google-fakes-attorney-client-privilege-by-ccing-lawyers-who-never-respond https://www.proskauer.com/blog/the-sound-of-silent-attorneys... — although they won later appeals. My point here is that its complicated.