California, United States of America
The following excerpt is from Scripps Health v. Superior Court, 109 Cal.App.4th 529, 135 Cal.Rptr.2d 126 (Cal. App. 2003):
distinction is not contained in statutes articulating the attorney-client privilege nor cases interpreting the scope of the privilege. (See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 601, 208 Cal.Rptr. 886, 691 P.2d 642 [no differentiation between factual and legal information].) It may be that the factual aspect of the reports will be revealed during some other aspect of discovery, but this does not make the occurrence reports discoverable.
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