Watkins v. Wilkinson

HARRIS, J. .

Plaintiff/Respondent testified on deposition that at times in the past when she had been questioned about her prior medical history she had forgotten to mention certain injuries or had been untruthful. A couple of days before her deposition, she referred to notes she had made in order to refresh her memory. Certain of these records were kept at the direction of her counsel and are work product.

However, she also referred to her “little notebook” which she started preparing shortly after the accident to keep track of the medical treatment she received. She compiled these notes just…