HEARING ON MOTION TO/FOR COMPEL RESPS TO FORM INTERR FILED BY
LUCAS GONZALES
* TENTATIVE RULING: *
Granted. As to Form Interrogatories 12.2 and 12.3, Coito v. Superior Court (2012) 54 Cal. 4th 480 requires that a party objecting to identifying or producing recorded statements or interviews on the grounds they are entitled to work product protection must make a preliminary or foundational showing that disclosure would reveal the attorney’s “impressions, conclusions, opinions, or legal research or theories.” Upon an adequate foundational showing, the Court then determines (including through an in camera inspection if necessary) whether and to what extent work product protection applies, thereby potentially shielding all or portions of interviews from discovery. Defendant has made no such showing.
Form Interrogatory 16.1 is not argumentative.
Verified answers without the objections shall be served by January 29, 2021. Sanctions denied.
Hearing Date
January 14, 2021
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HEARING ON MOTION TO/FOR COMPEL RESPS TO FORM INTERR FILED BY
LUCAS GONZALES
* TENTATIVE RULING: *
Granted. As to Form Interrogatories 12.2 and 12.3, Coito v. Superior Court (2012) 54 Cal. 4th 480 requires that a party objecting to identifying or producing recorded statements or interviews on the grounds they are entitled to work product protection must make a preliminary or foundational showing that disclosure would reveal the attorney’s “impressions, conclusions, opinions, or legal research or theories.” Upon an adequate foundational showing, the Court then determines (including through an in camera inspection if necessary) whether and to what extent work product protection applies, thereby potentially shielding all or portions of interviews from discovery. Defendant has made no such showing.
Form Interrogatory 16.1 is not argumentative.
Verified answers without the objections shall be served by January 29, 2021. Sanctions denied.