California Supreme Court Addresses Work Product Protection Applicable to Witness Identities and Recorded Interviews

In Coito v. Superior Ct., 54 Cal. 4th 480 (2012), the California Supreme Court addressed whether, and to what extent, the following items of evidence were entitled to attorney work product protection:  (1) recordings of witness interviews conducted by investigators employed by counsel, and (2) information concerning the identity of witnesses from whom counsel obtained statements. As to the interview recordings, the Court held that they

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