"How could you improve this paragraph to
better distill the takeaway at the start?
Try drafting a new first sentence.
"Where a party raises a claim which in fairness requires disclosure of the
protected communication, the privilege may be implicitly waived. United
States v. Ortland, 109 F.3d 539, 543 (9th Cir. 1997). A Section 2255
petitioner who asserts ineffectiveness of counsel as a ground for relief
may thereby place into issue his communications with trial counsel."
