(D.C.Cir.1980). But they differ in important ways, not the least of which is their treatment of factual material within documents. Factual portions of documents covered by the deliberative process privilege must be segregated and disclosed unless they are “so interwoven with the deliberative material that [they are] not[segregable].” United States v. Fernandez, 231 F.3d 1240, 1247 (9th Cir. 2000). The same is not true for documents withheld pursuant to the attorney work-product privilege. See id. That privilege shields both opinion and factual work product from discovery. Fed.R.Civ.P. 26(b)(3) (“Ordinarily, a party may not discover documents and tangible things that are prepared in anticipation of litigation....”); Hickman v. Taylor, 329 U.S. 495, 510, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (<HOLDING>); cf. Fed.R.Crim.P. 16(a)(2) (providing that as
holding that attorneys notes of client interviews are not discoverable absent a showing of necessity or justification holding trial court erred when it sanctioned client where the evidence showed that the attorney filed frivolous pleadings on behalf of the client but the client did nothing more than rely on her attorneys advice holding that an attorneys filing a notice of appearance on behalf of his or her client constitute a waiver of service of process by the client holding claims against attorney for legal malpractice must be asserted by attorneys actual client absent limited exception holding that attorneys acts within scope of his authority are binding on client