product is not sacrosanct where, as here, the advice of counsel is directly at issue. (Supplemental Memorandum). Case law supports Ferrara’s position. Although opinion work product requires a stronger showing than ordinary work product, it is not absolutely immune from discovery. See Micron Separations, Inc. v. Pall Corporation, 159 F.R.D. 361, 364 (D.Mass.1995). Rather, opinion work product is subject to discovery where the mental impressions of counsel are directly at issue. Holmgren v. State Farm Mutual Automobile Insurance Company, 976 F.2d 573, 577 (9th Cir.1992) (opinion work product subject to discovery “when mental impressions are at issue in a case and the need for the material is compelling”); Dixie Mill Supply Company, Inc. v. Continental Casualty Company, 168 F.R.D. at 559 (<HOLDING>); Hartman v. Banks, 164 F.R.D. 167, 170
holding that a request for admission is a tool of discovery subject to discovery cutoff dates holding that no heightened showing is required recognizing the compelling interest in highway safety holding that a discovery exception to a statute of limitation applies only to the discovery of facts not discovery of the law recognizing that opinion work product subject to discovery upon heightened showing of compelling need