Boring & Tunneling Co. of America, Inc. v. Salazar
This case involves a petition for writ of mandamus filed by the defendants (relators) in an underlying personal injury lawsuit. The relators, Boring & Tunneling Company of America, Inc. and Lee Arthur Evans, sought to prevent the discovery of certain documents, claiming they were protected by investigative and attorney-client privileges. The documents included an attorney's letter and file memo, and statements from Lee Arthur Evans and his son, Keith Evans, related to a fatal car accident. The trial court, presided over by Judge Felix Salazar, initially granted a protective order but later rescinded it, ordering the production of the disputed documents. On review, the appellate court determined that the relators failed to prove the applicability of investigative privileges because they did not provide objective evidence that the documents were prepared in anticipation of litigation. However, the court found that the attorney-client privilege applied to the attorney's letter to the claims adjuster, but not to the attorney's file memo (due to waiver) or Lee Arthur Evans' statement (due to conflicting evidence regarding the attorney-client relationship at the time). Consequently, the petition for writ of mandamus was conditionally granted in part, ordering the trial court to rescind its production order only for the attorney's letter to the adjuster, and denied for the other documents.