Are Preparatory notes or writings created to communicate to one's attorney protected even if they are not ultimately conveyed to the attorney?

California, United States of America


The following excerpt is from Shanahan v. The Superior Court Of Los Angeles County, B221164, No. B220947, No. BC413879 (Cal. App. 2010):

4. Preparatory notes or writings created for the purpose of communicating them to one's attorney are protected even if they are not ultimately conveyed to the attorney. (Cf. People v. Gardner (1980) 106 Cal.App.3d 882, 887.)

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