Conducted an investigation using terms of reference that established precedent for solicitor/client privilege protection of harassment investigation reports (Gower v Tolko Manitoba Inc., 2001 MBCA 11).

In the case of Gower v. Tolko Manitoba Inc., the employer had hired a lawyer to come into the workplace and investigate an allegation of sexual harassment that had been brought against one of its employees. The employer and the investigator entered into an agreement whereby the investigator would conduct the investigation, make recommendations and provide advice in respect to the legal implications of those recommendations. In addition, the investigator would also give advice on how the employer might go about minimizing the likelihood that a successful wrongful dismissal action, human rights complaint or union grievance could be brought. The employee then brought an action in wrongful dismissal, and brought a motion for the production of the investigator's report.

The issue then went before the Court, as to whether or not the document needed to be produced, or whether it was protected by solicitor-client privilege. The Court ultimately held that both the legal advice portion of the report and the fact-finding aspect of the report were privileged, as the facts had been gathered for the purpose of providing the legal advice. As such, the entire report was determined to be protected by legal advice privilege and did not have to be produced.