techniques and discovery procedures.” Fact work product traditionally protects that information which relates to the case and is gathered in anticipation of litigation. Opinion work product consists primarily of the attorney’s mental impressions, conclusions, opinions, and theories. Whereas fact work product is subject to discovery upon a showing of “need” and “undue hardship,” opinion work product generally remains protected from disclosure. Florida Rule of Civil Procedure 1.280(b)(3) permits the disclosure of work product if the party seeking discovery “has need of the materials in the preparation of the case and is unable without undue hardship to obtain the substantial equivalent of the materials by other means.” Id. at 1384, 1885 (Fla.1994) (citations omitted) (emphasis added) (<HOLDING>); cf. State, Dep’t of Health & Rehabilitative
recognizing that although the fourth circuit has not yet addressed the issue partial discharge may be granted to the extent that it would be an undue hardship for the debtor to have to pay that portion of the loan that is to be discharged holding that al though the material sought was work product the party seeking discovery showed that it would not be able to obtain the materials without undue hardship holding a party seeking mandamus must serve the party against whom relief is sought holding that it is not an undue hardship for a teacher to work a full calendar year holding that the party asserting work product protection has the burden of establishing that the doctrine applies