Work product doctrine covers
materials prepared by lawyer in anticipation of litigation
purpose of work product
to encourage thorough prep for cases
ordinary work product.
disclosure may be ordered for ordinary work product if opposing party shows the substantive ned and undue hardship in obtaining substantially equivalent of the material (this is the exception)
core work product
lawyers mental impressions generally protected from disclosure.
Duration of av privilege
seeking legal assistance, continuing, perpetual (continues after death)
MR. 1.6 comments 18 19
18- competence regarding safeguarding client info
19 need not use special precautions if reasonable expectation of privacy.
24/7 DUTY TO PROTECT clients