Does a defense counsel have a duty to obtain written statements from a witness?

^7. The prosecutor represented to the trial court that there was no report of the victim's undisclosed statements. That is irrelevant to the question of whether a discovery violation occurred. "While defense counsel does not have a duty to obtain written statements from witnesses [citation], counsel is not entitled to withhold any relevant witness statements from the prosecution by the simple expedient of not writing them down. '[S]uch gamesmanship is inconsistent with the quest for truth, which is the objective of modern discovery.' " (Roland v. Superior Court (2004) 124 Cal.App.4th 154, 165.)

^8. Defense counsel made a Griffin objection, which was overruled.