client or work product privileges. Plaintiff’s characterization of the Numerical Information as “purely factual” fails to take into account that the seemingly straightforward numeric results of Defendant’s assessments of Plaintiffs compliance with the CAA are not “purely factual,” but rather derive from raw data (that has been disclosed to Plaintiff) selected and ana lyzed pursuant to its own formulas by Defendant’s technical staff, scientists, and engineers, working in conjunction with or at the direction of attorneys. Id. ¶¶ 38, 46-47, 52. Therefore, the Numerical Information, albeit numeric, constitutes “mental impressions, conclusions, opinions, or legal theories” so as to satisfy the requirements of the work product privilege. See, e.g., Missoim Coalition, 542 F.3d at 1211 (<HOLDING>) (quotation omitted); MSB, 2012 WL 685334, at
holding that when the withheld evidence would seriously undermine the testimony of a key witness or there is no strong corroboration the withheld evidence has been found to be material holding that disclosure during discovery of certain kinds of information including privileged material trade secrets attorney work product or material involving a confidential informant could constitute a material injury of an irreparable nature holding that manufacturer could be estopped from asserting federal preemption of failuretowarn claim if manufacturer withheld material facts from environmental protection agency holding that purely factual material may be withheld from disclosure under exemption 5 if that material would expose the deliberative process of an agency holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege