Hardesty v. McCord & Holdren, Inc

In Hardesty v. McCord & Holdren, Inc. (1976) 41 Cal.Comp.Cases 111, the appeals board panel reviewed an order of the workers' compensation judge compelling the parties to provide each other with any witness statements in their possession. In an extended discussion about the application of the Civil Discovery Act to workers' compensation proceedings, the panel explicitly acknowledged that the attorney-client privilege required it to modify the order under review to "exempt from disclosure any matter or communication which is privileged within the meaning of the provisions of Division 8 of the Evidence Code." ( Id. at p. 116.)