Recordings of witness interviews conducted by investigators employed by counsel and the identity of witnesses from whom counsel obtained statements are subject to at least a qualified work product protection, the California Supreme Court has ruled. Coito v. Superior Court, No. S181712 (Cal. Jun. 25, 2012). In addition, the Court held such statements and information could be subject to absolute privilege if disclosure would reveal an attorney’s tactics, impressions, or evaluation of the case. The Court reversed an order compelling discovery and returned the case to the trial court.
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