CALIFORNIA EVIDENCE: CIVIL AND CRIMINAL
...Privileges
......Attorney Work Product
.........Examples of Items Not Protected
............Witness' Statements
3 Cards On This Topic:
  • D's holding cell statement to accomplice about possible witness did not come w/in work product privilege.
  • Where witnesses unable to recall contents of statements given to adversary, good cause is shown for production of those statements.
  • Qualified work product privilege protects list of potential Ws interviewed by opposing counsel but list of Ws who prepared independent stmts does not come under privilege.