March 24, 2026
Court of Appeal of the State of California, Fourth Appellate District, Division Three
The Rule of Guardian Storage Centers, LLC is that attorneys must comply with State Fund obligations when they receive attorney-client privileged materials that were impermissibly taken from the privilege holder without authorization, even when the materials were originally sent to the disclosing person in their corporate capacity, under circumstances where the person later provides the materials to their attorney in their individual capacity against the privilege holder.