Samaritan Health Services, Inc. v. Superior Court

CORCORAN, Judge,

dissenting.

I respectfully dissent.

I agree with the majority that Samaritan through its in-house counsel waived its claim of privilege regarding the “interview summaries which were delivered to Samaritan employees to refresh their recollections in preparation for deposition.” However, the predicate for requiring the trial court to examine the summaries in camera under rule 612, Arizona Rules of Evidence, is that there be a claim “that the writing contains matters not relating to the subject matter of the action.” Samaritan tacitly acknowledges that the summaries do relate to the subject matter of the action by indicating that they contain “mental impressions and subjective interpretations of corporate counsel.” Since there is no claim that they do not relate to the subject matter of the action, no in camera inspection is necessary. I would deny relief.