Notes an investigator took during witness interviews are not protected from discovery under the work-product doctrine, even if the investigator had been acting at the direction of an attorney, the Pennsylvania Superior Court has ruled.

A unanimous three-judge Superior Court panel ruled June 7 that an investigator working for the Archdiocese of Philadelphia as part of its effort to defend against sexual abuse allegations must turn over notes and summaries of witness interviews. The ruling in McIlmail v. Archdiocese of Philadelphia affirmed an order from the Philadelphia Court of Common Pleas.

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