the documents were protected” under the attomey-work-product doctrine. Id. at 343. The district court had denied the plaintiffs’ motion to compel, and the Fifth Circuit affirmed, holding that the plaintiffs had “failed to show that they have a substantial need for the documents or that production was necessary inthe interests of justice.” Id. The Honorable Eldon E. Fallon 4 March 23,2016 Numerous other courts — including the Third, Fourth, and Eighth Circuits — likewise have held that parties are not required to disclose what documents their counsel provided to their witnesses to review in preparation for a deposition because counsel’s compilation of those documents is opinion work product that is protected from disclosure. See, e.g., In re Allen, 106 F.3d 582, 608 (4th Cir. 1997) (<HOLDING>); Shelton v. Am. Motors Corp., 805 F.2d 1323,
holding that attorneys choice and arrangement of documents for witness preparation constitutes opinion work product because counsels selection and compilation of these particular documents reveals her thought processes and theories regarding this litigation holding declaration or affidavit must support work product claim for documents listed solely as work product on privilege log recognizing a general right to inspect and copy public records and documents including judicial records and documents holding that pursuant to the best evidence rule trial testimony relying on documents was inadmissible without submission of such documents or an explanation as to why the documents were unavailable holding that a party failed in meeting its burden that documents were work product because the party resisting discovery failed to present affidavits or other evidentiary support for its contention that the documents were prepared in anticipation of litigation