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was faced with the narrow question of ownership of notes, working
papers, drafts, and internal memoranda written by the attorney,
over which the client in that case asserted an ownership interest
superior to that of her attorney. Id. at 96. The materials in
issue in this case are distinguishable from those in the Corrigan
case because they are not petitioner’s work product and do not
contain his ideas, opinions, or impressions. See id.
Because the materials are not work product, it is not
necessary for us to determine in this case whether Oklahoma would
follow the majority or minority view with regard to ownership of
case files. We are aware of no court that has held that clients
have no ownership interests in their respective case files.
Rather, as we have summarized above, all jurisdictions that have
considered explicitly the issue of ownership of case files have
held that clients have superior property rights in at least those
items in the case file that are not the attorney’s self-created
work product. Those courts that have reserved a property right
to the attorney have done so only with regard to the attorney’s
personal notes, working drafts and papers, and internal
memoranda. The materials in issue in this case fall outside of
this work product exception. Thus, under either approach, the
documents in issue in this case belong properly to petitioner’s
client, McVeigh, and not to petitioner. Petitioner, in effect,
was merely the authorized and incidental custodian of the copies
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