Michael Peregrine and William Schuman wrote this bylined article about a trio of new state appellate court decisions that help define a general counsel’s client in a legal proceeding or investigation involving interaction with officers and/or directors. These new decisions “provide a timely and important opportunity for the general counsel to confirm fundamental representational matters with her internal clientele,” the authors wrote, and “also serve to underscore the importance of properly communicated ‘Upjohn’ warnings to corporate executives.”