Government Employees Insurance Co. v. Superior Cou
“The attorney-client privilege . . . confers a privilege on the client ‘to refuse to disclose, and to prevent another from disclosing, a confidential communication between client and lawyer . . . .’” (Costco Wholesale Corp. v. Superior Court (2009) 47 Cal.4th 725, 732 (Costco).) Courts “may not require disclosure of information claimed to be privileged . . . in order to rule on the claim of privilege . . . .” (Evid. Code, § 915, subd. (a) (section 915); see Costco, supra, at pp. 736-740.) “[S]ection 915 prohibits a court from reviewing an allegedly privileged attorney-client communication to determine whether it is privileged because the nature of the attorney-client privilege requires absolute protection for all confidential communications between an attorney and a client regardless of their content. [Citation.] Courts have no power to create exceptions to section 915’s mandate. [Citation.] The court therefore may not review the content of the communication to
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