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representation, which includes finalized legal documents,
pleadings filed, correspondence among parties, and other papers
“‘exposed to public light by the attorney to further [the]
client’s interests’”. In re Sage Realty Corp. v. Proskauer Rose
Goetz & Mendelsohn L.L.P., 689 N.E.2d at 881-882 (quoting Fed.
Land Bank v. Fed. Intermediate Credit Bank, 127 F.R.D. 473, 479
(S.D. Miss. 1989), modified 128 F.R.D. 182 (S.D. Miss. 1989));
see also Apa v. Qwest Corp., 402 F. Supp. 2d 1247, 1250 (D. Colo.
2005) (upon termination of representation, attorney must
surrender case file to client and the “cost of making a copy of a
client file by a withdrawing lawyer belongs to the lawyer, not
the client”; however, duplication costs may be charged to the
client for copies of the attorney’s work product); Loeffler v.
Lanser (In re ANR Advance Transp. Co.), 302 Bankr. 607, 614 (E.D.
Wis. 2003) (concluding that the difference between the majority
and minority rules is primarily who bears the burden of proving
need for disclosure or secrecy, respectively, with regard to the
attorney’s work product); Womack Newspapers, Inc. v. Town of
Kitty Hawk, 639 S.E.2d 96, 104 (N.C. Ct. App. 2007) (“anything in
a client’s file, which is in the hands of the client’s attorney,
belongs to the client, with the exception only of the attorney’s
notes or work product”). One State appellate court has held
explicitly that, while a client may be entitled to access his
attorney’s work product in order to understand the services
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