. Id. at 148-49. 47 . Id. at 149. 48 . Id. at 148-49. 49 . Id. 50 . Id. at 149. 51 . Id. 52 . Id. at 150. 53 . Id. at 150-51. 54 . Id. at 151-53 (rejecting an extension of Welfare Rights Org. v. Crisan, 33 Cal.3d 766, 190 Cal.Rptr. 919, 661 P.2d 1073 (1983)). 55 . Id. at 154-55. 56 . Id. at 152-54. 57 . See Bell v. Vill. of Streamwood, 806 F.Supp.2d 1052, 1056 (N.D.Ill.2011). Like the attorney client privilege, the union-relations privilege protects communications between union representatives and an employee's attorney. See Alaska Evid. R. 503(b). 58 . Because Peterson claimed the privilege, we have no occasion to address whether the union has a right to claim the privilege on its own behalf. 59 . See Upjohn Co. v. United States, 449 U.S. 383, 395, 101 S.Ct. 677, 66 L.Ed.2d 584 (1981) (<HOLDING>). For example, the State argues the
holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege 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 holding that governmental entities may assert attorneyclient privilege to prevent disclosure of information otherwise required by statute holding attorneyclient privilege protects disclosure of communications but does not protect client from disclosure of underlying facts holding that the attorneyclient privilege protects a clients identity only in limited circumstances where disclosure would convey the substance of a confidential professional communication