attorney-client privilege in California

2020Code,] § 951.)" (People v. Gionis (1995) 9 Cal.4th 1196, 1210 (Gionis); accord, City & County of San Francisco v. Superior Court (1951) 37 Cal.2d 227, 235 ["[O]nly communications made to an attorney in the course of professional employment are privileged."]; League of California Cities v. Superior Court (2015) 241 Cal.App.4th 976, 989 .) 11 It is well-settled that a public entity enjoys an attorney-client relationship with its lawyers and the attorney-client privilege protects communications made in the course of that relationship.

2020Code,] § 951.)" (People v. Gionis (1995) 9 Cal.4th 1196, 1210 (Gionis); accord, City & County of San Francisco v. Superior Court (1951) 37 Cal.2d 227, 235 ["[O]nly communications made to an attorney in the course of professional employment are privileged."]; League of California Cities v. Superior Court (2015) 241 Cal.App.4th 976, 989 .) 11 It is well-settled that a public entity enjoys an attorney-client relationship with its lawyers and the attorney-client privilege protects communications made in the course of that relationship.

2026A. Applicable Law “The attorney-client privilege . . . confers a privilege on the client ‘to refuse to disclose, and to prevent another from disclosing, a confidential communication between client and lawyer . . . .’ The privilege ‘has been a hallmark of Anglo-American jurisprudence for almost 400 years.’ [Citation.] Its fundamental purpose ‘is to safeguard the confidential relationship between clients and their attorneys so as to promote full and open discussion of the facts and tactics surrounding individual legal matters. [Citation.] . . . [¶] Although exercise of the privilege may occasion

2026In the first proceeding, we concluded that despite a “relationship . . . giving rise to the attorney-client privilege and work product protections,” Intuitive waived the privilege “by placing the scope and adequacy of the investigations at issue, . . . such that . . . disclosure of the material is ‘ “essential for a fair adjudication of the action.” ’ ” (Paknad v. Superior Court (May 20, 2024, H050711) [nonpub. opn.] (Paknad I), quoting Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.App.4th 110, 128 (Wellpoint).) While we stopped short of holding that Intuitive had necessarily

2025(Mitchell, supra, 37 Cal.3d at p. 601 .) Advice provided by an attorney in contemplation of threatened litigation has been found to be protected by the attorney-client privilege.

2024As our high court explained in Mitchell v. Superior Court (1984) 37 Cal.3d 591, 600 , the attorney-client privilege “covers the transmission of documents which are available to the public, and not merely information in the sole possession of the attorney or client.

2025“Open government is a constructive value in our democratic society. [Citations.] The attorney-client privilege, however, also has a strong basis in public policy and the administration of justice.” (Roberts, supra, 5 Cal.4th at p. 380 .) Lastly, we look to whether “[p]rivate enforcement is necessary and places a disproportionate financial burden on the plaintiff in relation to the plaintiff’s stake in the matter.” (Code Civ.

2025“Open government is a constructive value in our democratic society. [Citations.] The attorney-client privilege, however, also has a strong basis in public policy and the administration of justice.” (Roberts, supra, 5 Cal.4th at p. 380 .) Lastly, we look to whether “[p]rivate enforcement is necessary and places a disproportionate financial burden on the plaintiff in relation to the plaintiff’s stake in the matter.” (Code Civ.

2003The fact that the information contained in the communications might also be used for incidental purposes not entitled to the privilege is unimportant.” (Holm, supra, 42 Cal.2d at p. 509 .) Accordingly, we conclude that the trial court abused its discretion in ordering the occurrence reports be produced because they fall within the attorney-client privilege.

2001In the course of the city's investigation, the city's claims investigator obtained a signed statement from plaintiff, the bus driver made written reports to the city setting forth his version of the accident, and the city's "agents" took photographs at the scene of, and immediately following, the accident. ( Holm v. Superior Court, supra, 42 Cal.2d at p. 504 , 267 P.2d 1025 .) The trial court granted plaintiffs discovery motion for inspection of these items, and rejected defendant city's argument the statement, report, and photographs were protected by the attorney-client privilege.

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2025Citing Upjohn Co. v. United States (1981) 449 U.S. 383 , Commodity Futures Trading Com. v. Weintraub (1985) 471 U.S. 343 , and California State Bar Rules of Professional Conduct, rule 4.4, Sims maintained that the Brown email was covered by the attorney-client privilege and requested that Shepardson “immediately destroy the email[] and any copies.” The letter further said: “Caltrans will resist any attempt made by you to include the email in this action or to offer it as evidence at trial.

2025Citing Upjohn Co. v. United States (1981) 449 U.S. 383 , Commodity Futures Trading Com. v. Weintraub (1985) 471 U.S. 343 , and California State Bar Rules of Professional Conduct, rule 4.4, Sims maintained that the Brown email was covered by the attorney-client privilege and requested that Shepardson “immediately destroy the email[] and any copies.” The letter further said: “Caltrans will resist any attempt made by you to include the email in this action or to offer it as evidence at trial.

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2023Citing People v. Gionis (1995) 9 Cal.4th 1196 (Gionis), the court noted that a person’s communications with an attorney, even if involving a legal matter, are generally not protected by the attorney-client privilege if the communications have no relation to a professional relationship between that person and the attorney.

2022It is a curious argument, given that the crux of our holding rejecting the “fiduciary” and “current client” 40 exceptions in EWP was that “nothing in the Evidence Code suggests that a potential or actual conflict of interest . . . abrogates the attorney-client privilege.” (EWP, supra, 231 Cal.App.4th at p. 1233 , italics added.) In any event, because this isolated special verdict finding reflects only the jury’s interpretation of conflicting evidence on a single question unrelated to the existence of an attorney-client relationship, we fail to see why it compels us to disturb the trial court’s

2026Relevant to respondents’ arguments here, implied waiver may be shown by demonstrating “the client has put the otherwise privileged communication directly at issue and . . . disclosure is essential for a fair adjudication of the action.” (Southern Cal. Gas Co. v. Public Utilities Com. (1990) 50 Cal.3d 31, 40 (Southern Cal. Gas).) In contrast, “‘where the substance of the protected communication is not itself tendered in issue, but instead simply represents one of several forms of indirect evidence in the matter,’” there is no implied waiver of the attorney-client privilege.

2024Code, § 952.)” (Roberts v. City of Palmdale (1993) 5 Cal.4th 363, 371 .) Under the Evidence Code, “the attorney-client privilege applies to confidential communications within the scope of the attorney-client relationship even if the communication does not relate to pending litigation; the privilege applies not only to communications made in anticipation of litigation, but also to legal advice when no litigation is threatened.” 17 ( Roberts, supra, at p. 371 , citing Hoiles v. Superior Court (1984) 157 Cal.App.3d 1192, 1198 , and Southern Cal. Gas Co. v. Public Utilities Com. (1990) 50 Cal.3d 3

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2025Code, § 956, subd. (a).) “ ‘To invoke the Evidence Code section 956 exception to the attorney-client privilege, the proponent must make a prima facie showing that the services of the lawyer “were sought or obtained” to enable or to aid anyone to commit or plan to commit a crime or fraud.’ ” (State Farm Fire & Casualty Co. v. Superior Court (1997) 54 Cal.App.4th 625, 643 ; see Wells Fargo Bank v. Superior Court (2000) 22 Cal.4th 201, 213, fn. 4 .) A “mere assertion of fraud is insufficient.” (BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1262 .) We review a trial cou

2004(People v. Sinohui (2002) 28 Cal.4th 205, 212 [ 120 Cal.Rptr.2d 783 , 47 P.3d 629 ]; Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 396-397 [ 15 Cal.Rptr. 90 , 364 P.2d 266 ].) The attorney-client privilege may be waived.

2004(People v. Sinohui (2002) 28 Cal.4th 205, 212 [ 120 Cal.Rptr.2d 783 , 47 P.3d 629 ]; Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 396-397 [ 15 Cal.Rptr. 90 , 364 P.2d 266 ].) The attorney-client privilege may be waived.

2026(See Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.App.4th 110, 128 (Wellpoint).) The trial court stated “Guardian ha[d] not disclaimed an intention to assert this defense,” and relied on Wellpoint to conclude Guardian, therefore, could not assert the attorney-client privilege with respect to the emails.

2026The employer and its attorney refused production, citing the attorney-client privilege and the work product doctrine.” (Kaiser, supra, 66 Cal.App.4th at p. 1223 .) The court of appeal found the employer could not assert the attorney-client privilege or work product protection if it defended against the employee’s claims by relying on the adequacy of its investigation. 15 (Wellpoint, supra, 59 Cal.App.4th at p. 128 .) Its reasoning hinged on the fact that the employer’s attorney conducted the investigation.

2018The appellate court concluded "a former trustee is required to turn over all communications, including privileged communications, in the trust's legal files unless they can demonstrate that they retained the counsel with whom they communicated in a personal capacity and took affirmative steps to distinguish the purported personal advice from advice obtained in a fiduciary capacity." ( Id. at pp. 1197-1198, 216 Cal.Rptr.3d 61 .) The appellate court concluded its holding was compelled by the Supreme Court's holding in Moeller v. Superior Court, supra, 16 Cal.4th 1124 , 69 Cal.Rptr.2d 317 , 947 P

2018The appellate court concluded "a former trustee is required to turn over all communications, including privileged communications, in the trust's legal files unless they can demonstrate that they retained the counsel with whom they communicated in a personal capacity and took affirmative steps to distinguish the purported personal advice from advice obtained in a fiduciary capacity." ( Id. at pp. 1197-1198, 216 Cal.Rptr.3d 61 .) The appellate court concluded its holding was compelled by the Supreme Court's holding in Moeller v. Superior Court, supra, 16 Cal.4th 1124 , 69 Cal.Rptr.2d 317 , 947 P

2015(Suezaki v. Superior Court (1962) 58 Cal.2d 166, 176 [ 23 Cal.Rptr. 368 , 373 P.2d 432 ].) Stated differently, the attorney-client privilege attaches only if the information is transmitted “in the course of [the attorney-client] relationship.” (Evid.

2015(Suezaki v. Superior Court (1962) 58 Cal.2d 166, 176 [ 23 Cal.Rptr. 368 , 373 P.2d 432 ].) Stated differently, the attorney-client privilege attaches only if the information is transmitted “in the course of [the attorney-client] relationship.” (Evid.

2023A lay client should not be expected to make such distinctions in what can and cannot be told to the attorney at the risk of losing the attorney’s services.’ [Citation.] Further, in such situations, disqualification would do nothing to protect the attorney-client privilege because the client still has the information and may pass it on to new counsel, leaving the adversary in the same position.” (Id. at pp. 219-220; see Neal v. Health Net, Inc. (2002) 100 Cal.App.4th 831, 843-844 [holding no confidential information had been disclosed, but stating in dicta, even if it had been, “[d]isclosure to

2019Fund v. WPS, Inc. (1999) 70 Cal.App.4th 644 , 82 Cal.Rptr.2d 799 ( State Fund ), holding, when a lawyer comes into possession of materials that clearly appear to be protected by the attorney-client privilege and it is reasonably apparent the materials were made available through inadvertence (that is, without the holder of the privilege having waived it), the lawyer receiving the materials must refrain from examining the materials any more than is necessary to ascertain their privileged status and then must immediately notify the party entitled to the privilege about the situation. ( Rico , at

2022(In re Complex Asbestos Litigation (1991) 232 Cal.App.3d 572, 585 .) Among other instances, disqualification of counsel may be warranted if (1) counsel does not comply with the procedures set forth in State Fund, which are also now codified in rule 4.4 of the California Rules of Professional Conduct, for what to do if counsel inadvertently receives privileged documents, and (2) “other 10 factors compel disqualification.” (State Fund, supra, 70 Cal.App.4th at p. 657 ; Rico, supra, 42 Cal.4th at pp. 817, 819.) The procedures set forth in State Fund apply when a lawyer “inadvertent[ly]” receives

2022(In re Complex Asbestos Litigation (1991) 232 Cal.App.3d 572, 585 .) Among other instances, disqualification of counsel may be warranted if (1) counsel does not comply with the procedures set forth in State Fund, which are also now codified in rule 4.4 of the California Rules of Professional Conduct, for what to do if counsel inadvertently receives privileged documents, and (2) “other 10 factors compel disqualification.” (State Fund, supra, 70 Cal.App.4th at p. 657 ; Rico, supra, 42 Cal.4th at pp. 817, 819.) The procedures set forth in State Fund apply when a lawyer “inadvertent[ly]” receives

2025(See, e.g., Costco Wholesale Corp. v. Superior Court (2009) 47 Cal.4th 725, 732 [the attorney client privilege is “ ‘absolute and disclosure may not be ordered’ ”]; DP Pham LLC v. Cheadle (2016) 246 Cal.App.4th 653, 659 [reversing trial court for reviewing the content of confidential attorney-client communications to evaluate privilege]; see also Evid.

2025Dept. of Corporations v. SpeeDee Oil Change Systems, Inc., supra, 20 Cal.4th at p. 1146 .) “The attorney-client privilege protects the transmission of information regardless of the content or whether the information is discoverable from other sources. [Citation.] It attaches to a confidential communication between the attorney and the client and bars discovery of the entire communication, including unprivileged material.” (DP Pham LLC v. Cheadle (2016) 246 Cal.App.4th 653, 664 ; see Evid.

2026A. Applicable Law “The attorney-client privilege . . . confers a privilege on the client ‘to refuse to disclose, and to prevent another from disclosing, a confidential communication between client and lawyer . . . .’ The privilege ‘has been a hallmark of Anglo-American jurisprudence for almost 400 years.’ [Citation.] Its fundamental purpose ‘is to safeguard the confidential relationship between clients and their attorneys so as to promote full and open discussion of the facts and tactics surrounding individual legal matters. [Citation.] . . . [¶] Although exercise of the privilege may occasion

2025(McDermott, supra, 10 Cal.App.5th at p. 1106 .) State Fund held: “When a lawyer who receives materials that obviously appear to be subject to an attorney-client privilege or otherwise clearly appear to be confidential and privileged and where it is reasonably apparent that the materials were provided or made available through inadvertence, the lawyer receiving such materials should refrain from examining the materials any more than is essential to ascertain if the materials are privileged, and shall immediately notify the sender that he or she possesses material that appears to be privileged.

2013“The fundamental purpose of the attorney-client privilege is, of course, to encourage full and open communication between client and attorney.” (Meredith, supra, 29 Cal.3d at p. 690 .) This rationale acquires particular magnitude in the criminal context: “ ‘[A]s a practical matter, if the client knows that damaging information could more readily be obtained from the attorney following disclosure than from himself in the absence of disclosure, the client would be reluctant to confide in his lawyer and it would be difficult to obtain fully informed legal advice.’ . . .

2013However, “the attorney-client privilege is not strictly limited to communications, but extends to protect observations made as a consequence of protected communications.” (.Meredith, supra, 29 Cal.3d at p. 693 .) Here, Zimmerman maintains that the prosecution’s questions relating to her obtaining possession of the portfolio and mail seek information protected by the attorney-client privilege.

2020Chadbourne, Inc. v. Superior Court (1964) 60 Cal.2d 723, 737 ; Jessup v. Superior Court (1957) 151 Cal.App.2d 102, 110 [“‘It follows that where the communication between corporate employees and is embodied in reports or photographic evidence for the purpose of redelivery to a corporate attorney the privilege attaches if the reports and photographs were created as a means of communicating confidential information to the attorney’”].) After reviewing the report at issue, we conclude the trial court 4 did not abuse its discretion when it found the report subject to the attorney-client privilege.

2008Upjohn "recognized that in a corporate setting, the attorney-client privilege may extend to communications involving middle and lower level employees...." ( Zurich American Insurance Co. v. Superior Court, supra, 155 Cal.App.4th at p. 1497 , 66 Cal.Rptr.3d 833 .) Additionally, Upjohn "acknowledged the importance of legal advice to corporate employees at all levels. ..." ( Zurich American Insurance Co. v. Superior Court, supra, at p. 1498, 66 Cal.Rptr.3d 833 .) Chadbourne wished to provide the artificial entity with the same, but not greater, privileges as natural persons. ( Chadbourne, supra,

2021Section 6254, subdivision (k), “allows agencies to withhold ‘[r]ecords, the disclosure of which is exempted or prohibited pursuant to federal or state law, including, but not limited to, provisions of the Evidence Code relating to privilege.’ [Citation.] By ‘its reference to the privileges contained in the Evidence Code,’ section 6254(k) ‘has made the attorney-client privilege applicable to public records.’ [Citation.]” (Los Angeles County Bd. of Supervisors v. Superior Court (2016) 2 Cal.5th 282, 291 , fn. omitted (Los Angeles County Supervisors).) This exemption affords “ ‘public entities th

2021Section 6254, subdivision (k), “allows agencies to withhold ‘[r]ecords, the disclosure of which is exempted or prohibited pursuant to federal or state law, including, but not limited to, provisions of the Evidence Code relating to privilege.’ [Citation.] By ‘its reference to the privileges contained in the Evidence Code,’ section 6254(k) ‘has made the attorney-client privilege applicable to public records.’ [Citation.]” (Los Angeles County Bd. of Supervisors v. Superior Court (2016) 2 Cal.5th 282, 291 , fn. omitted (Los Angeles County Supervisors).) This exemption affords “ ‘public entities th

2024Relevant law “[T]here is no reason inherent in the nature of an attorney’s role as in-house counsel to a corporation that in itself precludes the maintenance of a retaliatory discharge claim, provided it can be established without breaching the attorney-client privilege or unduly endangering the values lying at the heart of the professional relationship.” (General Dynamics Corp. v. Superior Court (1994) 7 Cal.4th 1164, 1169 (General Dynamics).) “Except in those rare instances when disclosure is explicitly permitted or mandated by an ethics code provision or statute, it is never the business of

2014(Ibid.) Our Supreme Court concluded that the in-house attorney could pursue a wrongful discharge claim against his employer based on both theories: a violation of an implied agreement not to terminate except for cause; and a violation of public policy, based on retaliation, “provided it can be established without breaching the attorney-client privilege or unduly endangering the values lying at the heart of the professional relationship.” (General Dynamics, supra, 1 Cal.4th at pp. 1169, 1179, 1189.) As to the effect of attorney-client confidences on an in-house counsel’s ability to prove a reta

2014Engstrom demurred to the SAC, arguing the alleged confidential information about the source of the dirt used in the Malibu Construction Matter was a matter of public record and therefore not confidential; Engstrom was entitled to dismissal of the Allegro Matter claims because it could not mount an adequate defense without breaching the attorney-client privilege with respect to the other Allegro Matter plaintiffs under Solin v. O’Melveny & Myers (2001) 89 Cal.App.4th 451 (Solin); plaintiffs did not plead fraud with sufficient particularity; plaintiffs could not seek restitution because their cl

2014The court found that with respect to those claims based on the Allegro Matter (second, fourth, seventh, eighth, tenth, twelfth and thirteenth causes of action), the statute of limitations did not bar those claims even under the delayed discovery rule because plaintiffs alleged sufficient facts to show they did correspondence dated December 3, 2010 with Public Works requesting documents evidencing the placing of fill dirt at plaintiffs’ residence. 7 not discover their claim until November 2011.2 However, plaintiffs’ claims based on the Allegro Matter settlement were barred under Solin, supra, 8

2024Fund v. WPS, Inc. (1999) 70 Cal.App.4th 644 (“State Fund”).6 HFPA also disputed Quinto’s characterization of the note from counsel in the draft as “ministerial,” arguing it was advice relating to “conditions under which a non-profit is required to obtain certain approval from the California Attorney General.” Further, Sundholm and his attorney had a history of using “precisely [this] type of information” in “frivolous lawsuits” and “leaks to the press.” HFPA also argued that given One LLP’s 6 Pursuant to State Fund, supra, 70 Cal.App.4th at pages 656 to 657, “When a lawyer who receives materia

2024Fund v. WPS, Inc. (1999) 70 Cal.App.4th 644 (“State Fund”).6 HFPA also disputed Quinto’s characterization of the note from counsel in the draft as “ministerial,” arguing it was advice relating to “conditions under which a non-profit is required to obtain certain approval from the California Attorney General.” Further, Sundholm and his attorney had a history of using “precisely [this] type of information” in “frivolous lawsuits” and “leaks to the press.” HFPA also argued that given One LLP’s 6 Pursuant to State Fund, supra, 70 Cal.App.4th at pages 656 to 657, “When a lawyer who receives materia

2024Code, § 952.)” (Roberts v. City of Palmdale (1993) 5 Cal.4th 363, 371 .) Under the Evidence Code, “the attorney-client privilege applies to confidential communications within the scope of the attorney-client relationship even if the communication does not relate to pending litigation; the privilege applies not only to communications made in anticipation of litigation, but also to legal advice when no litigation is threatened.” 17 ( Roberts, supra, at p. 371 , citing Hoiles v. Superior Court (1984) 157 Cal.App.3d 1192, 1198 , and Southern Cal. Gas Co. v. Public Utilities Com. (1990) 50 Cal.3d 3

2001Even if the attorney-client privilege rested with the corporation alone, plaintiffs would not have been entitled to privileged information simply because they brought a derivative action. ( McDermott, Will & Emery v. Superior Court (2000) 83 Cal.App.4th 378, 385 , 99 Cal.Rptr.2d 622 ["California courts have refused to carve out a shareholder exception to the attorney-client privilege, even in a derivative action"]; see also Smith v. Laguna Sur Villas Community Assn. (2000) 79 Cal.App.4th 639, 644 , 94 Cal. Rptr.2d 321 ["There is no statutory exception for shareholders, even for closely held en

2006(People v. Lines (1975) 13 Cal.3d 500, 510 [ 119 Cal.Rptr. 225 , 531 P.2d 793 ].) There is no client-litigant exception to the attorney-client privilege that is comparable to the patient-litigant exception to the psychotherapist-patient privilege.

2006(People v. Lines (1975) 13 Cal.3d 500, 510 [ 119 Cal.Rptr. 225 , 531 P.2d 793 ].) There is no client-litigant exception to the attorney-client privilege that is comparable to the patient-litigant exception to the psychotherapist-patient privilege.