The scope of the attorney-client privilege and work product doctrine for internal investigation reports has once again been clarified by the D.C. Circuit in a False Claims Act case against defense contractor KBR, Inc.  In its most recent decision, the D.C. Circuit rejected whistleblower Harry Barko’s arguments that KBR’s internal investigation documents were rendered discoverable either because they had been used to prepare a 30(b)(6) witness or because KBR referred to its internal investigation in its summary judgment papers.