The work product documents are created by attorney in preparation of litigation. These documents contain the thought and impressions of the attorney and is generally not discoverable. I believe in this case Big Tug refusal to produce the documents are right. Largely due to the documents having the thoughts and impressions of an attorney, and if an attorney's thoughts and impressions were always discoverable lawyers would not feel free to be creative in drafting strategies for their clients, which may intern stop them from keeping records of their thought and impressions. Also, a lawyer's analysis or opinions generally receives greater protection than fact work. Unfortunately for Mrs. Sadd, her attorney could not show substantial need to obtain this information without undue hardship.