The California Court of Appeal held that occurrence reports prepared by hospital employees regarding changes in a deceased patient's condition while hospitalized were prepared "in anticipation of litigation" and were therefore protected from discovery in a wrongful death action brought by the deceased patient's estate. The court held that the occurrence reports, which were prepared pursuant to the hospital's risk management plan devised in order for the hospital to participate in a self-insurance program, were clearly designated confidential documents by the hospital's in-house counsel and were protected on the basis of the attorney-client privilege.