J.N.’s placement had Dr. Renehan excluded the parents from the communication. (Doc. 12 at 7). The court disagrees that Dr. Renehan intended to send the email to the parents but does not address the merits of plaintiffs’ IDEA claims at this juncture. 11 . To the extent that earlier decisions in this circuit adopted a strict approach to waiver in which inadvertent disclosure to a third party necessarily waives privilege, more recent authority has eschewed that approach. Compare United States v. Rockwell Int’l, 897 F.2d 1255, 1265 (3d Cir.1990) (“The attorney-client privilege does not apply to communications that are intended to be disclosed to third parties or that in fact are so disclosed.”), with Redland Soccer Club, Inc. v. Dep’t of Army of U.S., 55 F.3d 827, 856 (3d Cir.1995) (<HOLDING>), and In re Grand Jury (Impounded), 138 F.3d
holding that district court did not err in concluding after an evidentiary hearing that the immunity agreement between defendant and the government did not extend to the charge being prosecuted holding that the district court did not err in determining that inadvertent disclosure did not result in waiver holding that district court did not err in finding that similar scheme involved sophisticated means holding that trial court did not err holding that the inadvertent disclosure of a privileged document does not waive the attorneyclient privilege if attorney took all reasonable steps to avoid disclosure and asserted the privilege as soon as the disclosure became known