In Anwar v. Fairfield Greenwich Ltd., No. 09 Civ. 118 (S.D.N.Y. July 8, 2013), the court allowed plaintiff to discover communications between the defendant’s employees and defendant’s Dutch in-house lawyer. The Dutch in-house lawyer, though educated in law, had never been licensed in any jurisdiction. Under U.S. law, the attorney-client privilege still applies if the client had a reasonable belief that it was receiving advice from a licensed attorney; however, the reasonable belief exception did not apply here. The Dutch in-house lawyer did not hold himself out as a licensed attorney, and the defendant never signed a professional charter committing to honor the attorney’s independence—which is required under Dutch law when a corporation hires a licensed attorney to work in-house.