City of Long Beach v. Superior Court

In City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, one party served an interrogatory requesting a list of all nonexpert witnesses that his adversary intended to call at trial. The Court of Appeal held that such a list was clearly protected as qualified work product: "The complete list of trial witnesses sought in this case is a derivative product developed as a result of the initiative of counsel in preparing for trial. The forced revelation of this list would violate the work product doctrine because counsel's decision in this respect is strategic; it necessarily reflects his evaluation of the strengths and weaknesses of his case." (Id. at p. 73.)