Legal Opinion

Kittitas Cnty., Corp. v. Sky Allphin, Abc Holdings, Inc.

Washington Supreme Court

Decided March 16, 2017No. 93562-9PublishedCited by 10 opinions

1Opinion of the CourtWiggins, J.

*696¶ 1 We decide here two important aspects of the work product doctrine. First, were the e-mails exchanged between the Kittitas County and the Department of Ecology work product? Second, if the e-mails are work product, are they discoverable under the *1236Public Records Act (PRA), chapter 42.56 RCW? We hold that the e-mails are work product because they were prepared by or for Kittitas County in anticipation of litigation. Second, we hold that Kittitas County did not waive its work product protection because disclosure of the e-mails to Ecology never created a significant likelihood that an…

2Cases cited30 opinions

  1. Hickman v. TaylorSupreme Court of the United States · 1947
  2. United States v. NoblesSupreme Court of the United States · 1975
  3. Cowiche Canyon Conservancy v. BosleyWashington Supreme Court · 1992
  4. United States v. American Telephone & Telegraph Co.Court of Appeals for the D.C. Circuit · 1980
  5. United States v. Deloitte LLPCourt of Appeals for the D.C. Circuit · 2010

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3Cited by10 opinions

  1. G. BouSamra, M.D. v. Excela Health, Aplts.Supreme Court of Pennsylvania · 2019
  2. Aventis Pharmaceutical Inc, V Wa State Department Of RevenueCourt of Appeals of Washington · 2018
  3. Teresa Banowsky v. Guy Backstrom, D.c., D/b/a...Court of Appeals of Washington · 2018
  4. Asotin County v. Richard EgglestonCourt of Appeals of Washington · 2019
  5. Christopher Denney v. City of RichlandCourt of Appeals of Washington · 2022

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