or for a party, or by or for its representative. Tayler v. Travelers Ins. Co., 183 F.R.D. 67, 69 (N.D.N.Y.1998) (citing Compagnie Francaise d’Assurance Pour le Commerce Exterieur v. Phillips Petroleum Co., 105 F.R.D. 16, 41 (S.D.N.Y.1984); In re Grand Jury Subpoenas, 561 F.Supp. 1247, 1257 (E.D.N.Y.1982)). “[T]here is no work product immunity for documents prepared in the ordinary course of business prior to the commencement of litigation.” Tayler, 183 F.R.D. at 70. There are two types of work product recognized, ordinary work product and opinion work product, and generally opinion work product, including mental impressions, conclusions, opinions or legal theories, is entitled to nearly absolute protection. Holmgren v. State Farm Mutual Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir.1992) (<HOLDING>). Ordinary work product, by contrast, is
holding that opinion where product is entitled to nearly absolute protection with some limited exceptions recognizing first two exceptions recognizing exceptions to immunity holding opinion work product to be absolutely protected holding selsky entitled to absolute immunity