witness, show him documents and ask him questions, and then mask the entire preparation session in the cloak of work product protection would serve to facilitate even the most blatant coaching of a witness if it could not be the subject of inquiry. To allow the invocation of work product protection to succeed in such circumstances would leave the party taking a deposition with no remedy to determine how, if at all, a witness’s testimony was influenced, not by advice from the witness’s own counsel, but by suggestions from the questioner’s adversary, who, especially if possessing governmental power, was in a position to unfairly pressure the witness. See SR Int’l Bus. Ins. Co. Ltd. v. World Trade Center Props. LLC, No. 01 Civ. 929(JSM), 2002 WL 1334821, at *6 (S.D.N.Y. June 19, 2002) (<HOLDING>). By asking Blankfein what topics he recalls
holding that the protection of the work product rule continues after litigation has terminated holding defendants waived work product protection over emails that defense counsel sent to independent thirdparty witness with whom defendants did not share common interest holding interest in probing witnesss credibility and recollection a highly persuasive showing sufficient to defeat assertion of work product protection over predeposition interviews pursuant to rule 26b3 holding that defendants use of investigative report to refresh witnesss recollection waived defendants work product privilege as to that part of the report that related to the testimony offered holding that fedrcivp 26b3 does not require absolute protection for opinion work product and noting that these materials may be discovered and admitted when mental impressions are at issue in the case and the need for the materials is compelling