One of the boats owned by Big Tug & Company sank. Many employees of Big Tug were on this boat, and a few unlucky crew members did not survive. Big Tug, anticipating lawsuits by the families of the victims, immediately interviewed witnesses that were involved in the incident. The attorney conducting the interviews drafted notes documenting the interviews which were filled with his own impressions and thoughts of the witness testimony. Mrs. Sadd filed a wrongful death action against Big Tug to recover for the loss of her husband. Mrs. Sadd's attorney filed an interrogatory requesting these interview notes. Big Tug refused citing the work product doctrine. Who is right and why?