In what circumstances have the courts found that disclosure of attorney prepared analyses and evaluations was improper?

In Sheets v. Superior Court, supra, 257 Cal.App.2d at pp. 10--11, 64 Cal.Rptr. 753, disclosure of attorney prepared analyses and evaluations of an accountant's written report and an estimator's oral reports was held improper. While the issue was decided on the basis of the attorney-client privilege, the court indicated that had the issue of work product been raised in the trial court, it would have ruled that the analyses were in the category of work product, 'not discoverable under any circumstances.' (257 Cal.App.2d at p. 10, n. 2, 64 Cal.Rptr. 753.)

In People v. Boehm, 270 Cal.App.2d 13, 21, 75 Cal.Rptr. 590, 595, it was contended that 'the court erred in refusing to allow inspection of 'notes made by the district attorney' relating to 'notes, memoranda, or records pertaining to the interviews, dates (and) persons present between the district attorney's office' and the (particular) immunized witness.' The [64 Cal.App.3d 81] court ruled that the desired information was covered by the work product privilege.