California, United States of America
The following excerpt is from People v. Garcia, B253462 (Cal. App. 2015):
2. See Vela v. Superior Court (1989) 208 Cal.App.3d 141, 144 [city cannot use attorney-client privilege to bar criminal defendants from seeking pretrial discovery of "statements made by its police officers to an investigating team organized by the city's police department to gather and preserve evidence for use by the city attorney in the defense of a possible future civil action"]; see also Rezek v. Superior Court (2012) 206 Cal.App.4th 633, 637 [statements of witnesses to the crime are discoverable notwithstanding that they were obtained as the result of an internal affairs investigation and placed in an officer's personnel file].
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