Seyfarth Shaw LLP | www.seyfarth.com Litigating CA Wage & Hour Class and PAGA Actions (24th Edition) 175 opinions, legal research or theories.893 The trial court may then determine whether and to what extent the absolute privilege applies.894 The Supreme Court’s decision in Coito expanded work product protection for witness interviews and signed declarations in California state courts. This case also highlights the importance of involving legal counsel as early as possible in order to protect witness interviews and declarations through the attorney work product doctrine. Interviews should be conducted by counsel, or at the direction of counsel, as the work product of non-attorney investigators may be subject to discovery. 893 Id. 894 Id.
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