R.Civ.P. 26(b)(3) (creating qualified privilege for materials prepared “in anticipation of litigation or for trial,” and adding that the privilege may be overcome upon a showing of “substantial need” and the inability to obtain substantially equivalent materials by other means “without undue hardship”). Even those evidentiary privileges occasionally spoken of as absolute, including the attorney-client privilege and the protection for so-called “opinion” work product, may be overcome upon a sufficiently powerful showing of relevance, need and hardship. See, e.g., In re Grand Jury Investigation (Schroeder), 842 F.2d 1223, 1226 (11th Cir.1987) (recognizing crime-fraud exception to the attorney-client privilege); Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir.1992) (<HOLDING>) (citations and emphasis omitted); Fausek v.
holding that materials prepared by an investigative audit committee were not work product because they were not the mental impressions conclusions opinions or legal theories of an attorney holding that opinion where product is entitled to nearly absolute protection with some limited exceptions holding opinion work product may be discovered when mental impressions are at issue and need for material is compelling holding that fedrcivp 26b3 does not require absolute protection for opinion work product and noting that these materials may be discovered and admitted when mental impressions are at issue in the case and the need for the materials is compelling holding that opinion work product is entitled to nearly absolute protection with limited exceptions