The Supreme Court of Ohio's Board of Commissioners on Grievances & Discipline issued an advisory opinion about whether a attorney's notes must be turned over to a client when requested.
Opinion 2010-2, rendered April 9th., finds that it depends upon whether “the notes are items reasonably necessary to the client’s representation” pursuant to Prof. Cond. Rule 1.16(d), which requires the lawyer to exercise his or her professional judgment.
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