important at the discovery stage. Vythoulkas v. Vanderbilt Univ. Hosp., 693 S.W.2d 350, 359 (Tenn.Ct.App.1985); Federal Practice and Procedure § 2008, at 99. However, it is more loosely construed during discovery than it is at trial. The phrase "relevant to the subject matter involved in the pending action” has been construed "broadly to encompass any matter that bears on, or that reasonably could lead to other matter that could bear on, any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351, 98 S.Ct. 2380, 2389, 57 L.Ed.2d 253 (1978); Hickman v. Taylor, 329 U.S. at 501, 67 S.Ct. at 388. 26 . Tenn. R. Civ. P. 26.02(1) & 26.02(3). 27 . Tenn. R. Civ. P. 26.02(3). 28 . See also Resolution Trust Corp. v. Dabney, 73 F.3d 262, 266 (10th Cir.1995) (<HOLDING>); Hodges, Grant & Kaufmann v. United States,
holding that the party asserting notice error has the burden of demonstrating prejudice holding the law presumes that a cause lies outside the limited jurisdiction of the federal courts and the burden of establishing the contrary rests upon the party asserting jurisdiction holding that the burden of proof lies on the party asserting the protection of the work product doctrine holding that the party asserting work product protection has the burden of establishing that the doctrine applies holding that the protection of the work product rule continues after litigation has terminated