the supreme court's unanimous reversal of the conviction reinforces the opinion that the jury should not have inferred any liability on arthur andersen based solely upon the october 16 memo. rather, ms. temple's bar license required that she not do anything that would waive the "attorney-client" privilege of enron or arthur andersen. by having her name and a legal reference removed, in effect she was making the subject memo suitable for public disclosure – it was no longer a "privileged" document.