Clarkson Industries, Inc. v. Price

Deen, Presiding Judge.

Appellant relies on the "work product” exception to the otherwise broad scope of discovery envisioned by Code Ann. § 81A-126 (b) (1). The work product doctrine stems from Hickman v. Taylor, 329 U. S. 495 (67 SC 385, 91 LE 451), in which the United States Supreme Court refused to require discovery of statements of witnesses obtained by an attorney after a claim arose but prior to litigation. Under our former discovery law, Code Ann. § 38-2101 et seq., it was held that "work product” included oral statements taken by an attorney from witnesses. Setzers Super Stores of Ga.…