In my opinion, Pennsylvania’s discovery Heartbeat team Coleman lifetime member shirt, that potentially includes attorney investigative notes, are problematic because they basically discourage attorneys from taking good notes. No attorney wants a careless note to affect the client’s case; and sometimes my notes would include hearsay or speculation, but it would be hard to always delineate those statements as such in the context to contemporaneous notes. As you can also see, Pennsylvania’s discovery rules do afford greater protection for attorney notes than a non-attorney. Accordingly, there may be situations where a client determines that it is best if an actual attorney goes to an accident or problematic scene to conduct an investigation.
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