Vuz

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Ashley R. VUZ, Case No.: 20-cv-0246-GPC-AGS Plaintiff, ORDER ON DEFENDANTS’

DISCOVERY MOTION

v. (ECF 116 & 119) DCSS III, INC., et al., Defendants. 8 Federal Rule of Evidence 612 permits the opposing party to inspect writings used to refresh a witness’s memory. But what if that writing is privileged? Does Rule 612 trump the privilege? This discovery dispute turns on that question. BACKGROUND After plaintiff Ashley Vuz’s allegedly improper arrest, she called attorney Ryan Graham for help. (See ECF 117, at 1.) Graham asked her to draft “a diary-like narrative of the events . . . for the purpose of evaluating Plaintiff’s potential case.” (ECF 119-1, at 17; see also ECF 117-1, at 2.) Vuz did so, gave those notes to Graham, and eventually hired him as counsel. (ECF 117-1, at 1-2.) After Vuz’s criminal case was dropped, Graham helped her bring this civil-rights suit. At her deposition, Vuz said that she…