CALIFORNIA EVIDENCE: CIVIL AND CRIMINAL
...Privileges
......Attorney Work Product
.........Expert's Reports/Documents
............Good Cause for Discovery
5 Cards On This Topic:
  • Burden is on party claiming item as work product to show need for protection.
  • Good cause for discovery of expert's report includes showing that s/he may be called as witness.
  • Cannot prohibit party from taking deposition of expert when object no longer available or altered so like tests would be impossible.
  • Good cause for discovery of expert's report includes showing no adequate substitute available.
  • Bringing additional D into case close to trial not good cause to get other party's expert advisor report. Solution is continuance.