doctrine contained in Exemption 5 of the Freedom of Information Act, "attorney work product is exempt from mandatory disclosure without regard to the status of the litigation for which it was prepared.” FTC v. Grolier Inc., 462 U.S. 19, 28, 103 S.Ct. 2209, 2215, 76 L.Ed.2d 387 (1983); see also 5 U.S.C. § 552(b)(5) (exempting from mandatory public disclosure "inter-agency or intra-agency memorandums or letters which would not be available by law to a party ... in litigation with the agency”). In reaching this decision, the Court stated that it was "not rely[ing] exclusively on any pa C.Cir.1982) (requiring showing of extraordinary justification to overcome protection of opinion work product), with Duplan Corp. v. Moulinage et Retorderie de Chavanoz, 509 F.2d 730, 735 (4th Cir.1974) (<HOLDING>). The Supreme Court has not yet decided whether
holding declaration or affidavit must support work product claim for documents listed solely as work product on privilege log holding that investigative report regarding potential premises liability claim was protected work product holding opinion work product to be absolutely protected holding that opinion work product is entitled to nearly absolute protection with limited exceptions holding opinion work product may be discovered when mental impressions are at issue and need for material is compelling