Hwang-Meza v. Gates Foundation

May 7, 2026
2:26-cv-01073

ORDER

Before the court is pro se Plaintiff Shihwa Hwang-Meza’s motion for limited in camera review and related relief. (Mot. (Dkt. # 7); Reply (Dkt. # 15).) Defendant the Gates Foundation opposes the motion. (Resp. (Dkt. # 14).) The court has reviewed the parties’ submissions, the relevant portions of the record, and the governing law. Being fully advised, the court DENIES Ms. Hwang-Meza’s motion.

Ms. Hwang-Meza brings employment discrimination, failure to accommodate, retaliation, and related claims arising from her employment with the Gates Foundation. (See generally Am. Compl. (Dkt. # 10).) The Gates Foundation has a website called EthicsPoint through which individuals can report concerns about potential violations of the Gates Foundation’s code of conduct. (See Hwang-Meza Decl. (Dkt. # 7-1) ¶ 5, Ex. 3 (EthicsPoint website).) On that site, the Gates Foundation identifies attorney Pallavi Wahi, its “external legal counsel at Arnold & Porter [Kaye Scholer LLP (‘Arnold & Porter’),]” as one of six individuals “who are familiar with and committed to ensuring compliance with the [Gates Foundation’s] policies and Code of Conduct[.]” (Id.) Two attorneys from Arnold & Porter, neither of whom is Ms. Wahi, represent the Gates Foundation in this action. (See NOA (Dkt. # 5).)

Ms. Hwang-Meza now asks the court to conduct an in camera review:

of limited materials sufficient to determine whether [Ms. Wahi] has a conflict of interest arising from her current role as external legal counsel to Defendant Gates Foundation and her public identification on the Foundation’s EthicsPoint webpage as a person familiar with, and committed to ensuring compliance with, the Foundation’s policies and Code of Conduct.

(Mot. at 1.) In a letter to counsel for the Gates Foundation, Ms. Hwang-Meza represented that she “need[s] to understand whether Ms. Wahi had any prior involvement in matters substantially related to this case or access to confidential information material to this dispute” because her claims “concern[] [her] employment, internal complaints, and related compliance issues[.]” (Hwang-Meza Decl. ¶ 2, Ex. 1) Counsel responded that “Arnold & Porter is not aware of any conflict that would preclude its representation of the Gates Foundation, and [does] not intend to provide further substantive information regarding [its] client relationships or internal conflict analysis.” (Id. ¶ 4, Ex. 2.)

In camera review is appropriate only where the movant presents “a factual basis adequate to support a good faith belief by a reasonable person” that the review will reveal evidence relevant to the claims at issue. United States v. Zolin, 491 U.S. 554, 572 (1989) (citation omitted and cleaned up). The court agrees with the Gates Foundation that Ms. Hwang-Meza’s suspicion that a conflict of interest could arise from Arnold & Porter acting as its external counsel in both compliance and litigation is purely speculative and does not justify in camera review of materials regarding Ms. Wahi’s Gates Foundation work. (See generally Resp.) Ms. Hwang-Meza cites no authority that would support a finding of a conflict of interest under the facts presented here. (See generally Mot.; Reply.) For example, neither of the Rules of Professional Conduct on which Ms. Hwang-Meza relies apply in this case because she is not a current or former client of Arnold & Porter. (See Mot. at 3-4 (citing Wash. RPC 1.7(a), 1.9)1); see Burnell v. Lewis Brisbois Bisgaard & Smith LLP, No. C22-0265JLR, 2022 WL 2237213, at *2 (W.D. Wash. June 22, 2022) (finding no conflict of interest where plaintiff, who previously worked for but was not a client of the defendant law firm, moved to disqualify the defendant law firm

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from representing itself in the litigation). Therefore, the court DENIES Ms. Hwang-Meza’s motion for in camera review (Dkt. # 7).

Dated this 7th day of May, 2026.

JAMES L. ROBART

United States District Judge

Notes

1
Rule 1.7(a)(2) provides that a lawyer shall not represent a client if “there is a significant risk that the representation of one or more clients will be materially limited by the lawyer’s responsibilities to another client, a former client or a third person or by a personal interest of the lawyer.” Wash. RPC 1.7(a)(2). Rule 1.9 governs a lawyer’s duties to former clients and prohibits a lawyer from representing a person whose interests are adverse to a former client or from using or revealing information relating to a former client to the disadvantage of that former client. Wash. RPC 1.9.