The Second Appellate District granted a petition for writ of mandate. The court held that that the attorney-client privilege is not limited to communications directly between a client and his or her attorney. The court further held that the absolute work product privilege depends not on the existence of a writing but rather on the nature of the claimed privileged matter.

Front Gate Plaza LLC operated a shopping mall. Primero Management provided management and accounting services for Front Gate. Raymond Arjmand worked both as a managing member of Front Gate and as a principal of Primero.