CALIFORNIA EVIDENCE: CIVIL AND CRIMINAL
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Privileges
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Attorney Work Product
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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.