the release pending resolution of a motion to vacate the order. The stay however, did not apply to documents posted by Congress on the Internet, which included the R & D Memo. 2. Whether RJR Waived Its Privileges When It Entered into the Settlement Agreement/Consent Judgment in the Minnesota Philip Morris Case Magistrate Judge DiBianco found that RJR waived any privileges when it entered into the consent judgment in Philip Morris permitting the plaintiffs to seek public disclosure of those documents for which a privilege was claimed but found not to exist. Magistrate Judge DiBianco cannot be said to have misapplied the law upon which he relied for his conclusion. See United States v. International Bhd. of Teamsters, 961 F.Supp. 666, 678 (S.D.N.Y.1997), aff'd 119 F.3d 210 (2d Cir.1997) (<HOLDING>); Grumman Aerospace Corp. v. Titanium Metals
holding that the attorneyclient privilege protects a clients identity only in limited circumstances where disclosure would convey the substance of a confidential professional communication holding that a party waives the attorneyclient privilege when it voluntarily consents to the disclosure of any significant part of the communication in issue holding that a claim for ineffective assistance of counsel waives attorneyclient privilege 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 an invocation of the advice of counsel defense waives the attorneyclient privilege