written materials, charts, notes of conversations and investigations, and other
materials directed toward preparation of a case or other legal representation. Their
importance is that they cannot be required to be introduced in court or otherwise
revealed to the other side. Sometimes there is a question as to whether documents
were prepared by the attorney and/or the client for their use in the case preparation
or are documents which are independent and legitimate evidence.
See also attorney-client privilege privileged communication work product
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