Nacht & Lewis Architects, Inc. v. Superior Court

Real party in interest (plaintiff) filed a civil complaint against petitioners (defendants) regarding her former employment with defendant Nacht & Lewis Architects, Inc. In response to Judicial Council approved form interrogatory No. 12.1, defendants provided the names of seven persons who witnessed, or who defendants claimed had knowledge of, the “incident,” defined as “the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding.” However, defendants objected to and refused to answer interrogatories requesting the identity of and information regarding individuals interviewed concerning the incident (form interrogatory No. 12.2) and individuals from whom written or recorded statements were obtained concerning the incident (form interrogatory No. 12.3). Defendants’ responses to interrogatories Nos. 12.2 and 12.3 were identical: “Counsel for the Defendants has conducted interviews of employees of Nacht & Lewis Architects. The information collected from the interviews is protected by the attorney-client privilege and work product doctrine.”

By order dated March 7, 1996, the…