In Nacht & Lewis Architects, Inc. v. Superior Court (1996) 47 Cal.App.4th 214, the plaintiff sought production of witness statements and propounded form interrogatory No. 12.3--the same two discovery requests at issue in the present case. The appellate court was unsure whether the sought-after witness statements had been made by the witnesses on their own initiative and then turned over to counsel for the defense or, instead, had been taken by counsel. As to the former, the court noted that no work product protection was available either as to the statements or as to a list of such witnesses. (Nacht & Lewis, supra, 47 Cal.App.4th at pp. 217-218.) As to the latter, however, the court stated: "A list of the potential witnesses interviewed by defendants' counsel which interviews counsel recorded in notes or otherwise would constitute qualified work product because it would tend to reveal counsel's evaluation of the case by identifying the persons who claimed knowledge of the incident from whom counsel deemed it important to obtain statements. Moreover, any such notes or recorded statements taken by defendants' counsel would be protected by the absolute work product privilege because they would reveal counsel's 'impressions, conclusions, opinions, or legal research or theories' ... ." (Id. at p. 217) In Nacht & Lewis, the Court of Appeal indicated that whenever an attorney records in writing the substance of a witness's statement, all of the written notes or recorded statements are protected by the absolute work product privilege. (Nacht & Lewis, supra, 47 Cal.App.4th at p. 217 "any such notes ... protected by the absolute work product".)