General Motors Corp. v. Gayle

I believe the respondent’s order improperly infringes upon both the work product privilege and the consulting expert exemption.

The work product privilege found in Rule 166b of the Rules of Civil Procedure protects from discovery the mental impressions, conclusions, opinions, and theories held or considered by counsel in his preparation for trial. Owens v. Wallace, 821 S.W.2d 746, 748 (Tex.App.—Tyler 1992, orig. proceeding). Here, the real parties in interest contend the privilege is not violated by the respondent’s order because they seek only to observe “neutral facts and testing.” They…