Jeremy Wilson drowned in a river in Modesto, California when he was 13 years old. Six juveniles witnessed the drowning. Debra Coito (plaintiff), Jeremy’s mother, sued several defendants for wrongful death, including the State of California (State) and the City of Modesto (defendants). The State’s investigators interviewed four of the witnesses. The investigators used a list of questions prepared by the State’s attorneys in the interviews and recorded the audio of each interview. During discovery, Coito served an interrogatory on the State requesting the names of everyone who had provided written or recorded statements. Coito also requested the audio recordings of the interviews. The State objected to both requests, citing the attorney work-product privilege. Coito filed a motion to compel responses to these requests. Without reviewing the recordings, the trial court found that the work-product privilege applied and denied the motion. Coito appealed. The Court of Appeal reversed, holding that, as a matter of law, the work-product privilege did not apply to either the interview list or the recordings. The State petitioned the California Supreme Court for review.