CRE 501

History

ANNOTATION Law reviews. For comment ‘‘Reporter’s Privilege: Pankratz v. District Court’’, see 58 Den. L.J. 681 (1981). For article, ‘‘Rule 501: The Privilege of Self-Critical Analysis’’, see 24 Colo. Law. 1291 (1994). Rule applies to all stages of an action and is applicable to pretrial discovery. Sherman v. Dis- trict Court, 637 P.2d 378 (Colo. 1981). Third persons may testify to overheard confidential conversations. If parties sustain- ing confidential relations to each other hold their conversation in the presence and hearing of third persons, whether they be necessarily present as police officers or indifferent bystand- ers, such third persons are not prohibited from testifying to what they heard. People in Interest of R.G., 630 P.2d 89 (Colo. App. 1981). News reporter has no privilege to refuse to respond to subpoena. Where a news reporter, who is a first-hand observer of criminal con- duct, is subpoenaed to testify and to produce relevant documents in the course of a valid grand jury investigation or criminal trial, there is no privilege under the Colorado constitution to refuse to respond to a subpoena. Pankratz v. District Court, 199 Colo. 411, 609 P.2d 1101 (Colo. 1980). Hospital inspection committees’ privilege not expanded. Absent legislative action and in light of the general policy favoring liberal dis- covery, the public interest in the confidentiality of hospital inspection committees is insufficient to warrant judicial expansion of the privilege contained in § 12-43.5-102(3)(e). Sherman v. District Court, 637 P.2d 378 (Colo. 1981).