WYOMING COURT RULES

82 Wide latitude allowed in interrogatories to party. — A proper interpretation of this rule admits of great latitude in the examination of a party by interrogatory. If the answer to a ques- tion may lead to the discovery of evidence or enlighten as to some phase of the issues, the interrogatory is permissible. Ulrich v. Ulrich, 366 P.2d 999, 1961 Wyo. LEXIS 136 (Wyo. 1961). But interrogatories are improper where they propound the ultimate questions to be decided by the court. — Ulrich v. Ulrich, 366 P.2d 999, 1961 Wyo. LEXIS 136 (Wyo. 1961). And where opinions based on legal con- clusions. — An interrogatory may be used to obtain admission as to a relevant fact, but this does not extend to its use to elicit an expression of opinion as to existence of what may become a fact only by virtue of a correct legal conclusion. Ulrich v. Ulrich, 366 P.2d 999, 1961 Wyo. LEXIS 136 (Wyo. 1961). Answers calling for opinions which would have been legal conclusions not within the party’s knowledge and respecting matter she was not qualified to answer may not be secured by interrogatories. Ulrich v. Ulrich, 366 P.2d 999, 1961 Wyo. LEXIS 136 (Wyo. 1961). Requiring answers to interrogatories discretionary. — The district court has a broad discretion in deciding whether to require answers to interrogatories. Mauch v. Stanley Structures, 641 P.2d 1247, 1982 Wyo. LEXIS 309 (Wyo. 1982). Surmise insufficient to justify produc- tion of documents. — Although a party is entitled to production of documents that would be useful to impeach a witness, his mere sur- mise that he might find impeaching matter has been held not sufficient to justify production. Thomas v. Harrison, 634 P.2d 328, 1981 Wyo. LEXIS 374 (Wyo. 1981). When insured’s report on claim privi- leged and not discoverable. — A report or other communication, made by an insured to his liability insurance company, concerning an event which may be made the basis of a claim against him covered by the policy, is a privi- leged communication, as being between attor- ney and client, if the policy requires the com- pany to defend him through its attorney and the communication is intended for the informa- tion or assistance of the attorney in so defend- ing him; therefore, the report or communication is not discoverable. Thomas v. Harrison, 634 P.2d 328, 1981 Wyo. LEXIS 374 (Wyo. 1981). Estimations of liability and damages deemed nondiscoverable work product. — A practice, used by many attorneys in the evaluation of their cases, is to inquire of a stenographer, an elevator operator, a barber and other contacts concerning their estimation of damages which they would award under given circumstances or their determination of the liability of parties under given circum- stances; this practice is a form of work product and is not subject to discovery. Thomas v. Har- rison, 634 P.2d 328, 1981 Wyo. LEXIS 374 (Wyo. 1981). Documents encompassing legal advice or evaluation privileged. — Documents sought to be produced in discovery — including letters from counsel to the client encompassing legal advice, in-house correspondence of the client discussing advice furnished by the attor- ney, reports of summaries of deposition testi- mony, and evaluations of the client’s position made by counsel — were privileged or arguably privileged. Continental Ins. Co. v. First Wyo. Bank, N.A. - Jackson Hole, 771 P.2d 374, 1989 Wyo. LEXIS 95 (Wyo. 1989). Written report not required. — Trial court’s order did not require the counselor to submit a written report to the mother, as the counsel was not specifically retained for the case, but to treat the children and east the trauma of the planned move. Tracy v. Tracy, 2017 WY 17, 388 P.3d 1257, 2017 Wyo. LEXIS 17 (Wyo. 2017). Trial court’s order did not require the coun- selor to submit a written report to the mother, as the counsel was not specifically retained for the case, but to treat the children and ease the trauma of the planned move. Tracy v. Tracy, 2017 WY 17, 388 P.3d 1257, 2017 Wyo. LEXIS 17 (Wyo. 2017).