Simmons v. Safeway, Inc., No. 3:18-cv-5522 RJB (W.D. Wash. June 5, 2019).
Key Insight: Handwritten notes by Plaintiff had been produced. Plaintiff used attorney typed version to refresh memory before deposition. Court ordered production of typed notes.
Nature of Case: Employment Discrimination
Electronic Data Involved: Typed version of handwritten notes
Keywords: recollection refresh; deposition; privilege; work product