Posted by Howard S. Schiffman on September 29, 2001 at 03:22:21:
In Reply to: The extents of the attorney/client privilege in Europe posted by Conrad Nowak on September 25, 2001 at 10:11:06:
Dear Conrad Nowak,
Both the common law legal system, like that of the United States and United Kingdom, and the civil law legal system, as practiced in continental Europe, do indeed recognize what we in the United States call attorney-client privilege. The different systems, however, apply variations on the concept systemically and nationally. The term used in Europe is more often referred to as "secret professionnel." For a fairly good essay on legal privilege versus secret professionnel take a look at: http://www.ecla.org/gb/paper/versus.htm.
I hope this helps. Please feel free to post any follow-ups on your inquiry. Best of luck.
Howard S. Schiffman, Esq.
Co-Founder and Administrator
www.InternationalLawHelp.com
: Could anyone point me to a source which may address the applications of privilege in Europe?