States v. Bryan, 339 U.S. 323, 331, 70 S.Ct. 724, 730, 94 L.Ed. 884 (1950); see also United States v. Nixon, 418 U.S. 683, 709-10, 94 S.Ct. 3090, 3108-09, 41 L.Ed.2d 1039 (1974) (noting that privileges should not be “lightly created nor expansively construed, for they are in derogation of the search for truth”). In order to breathe life into these principles, courts have been loathe to recognize absolute privileges. The closest analog to the privilege now sought by American— the self-critical analysis privilege — has been viewed as a qualified privilege that may be overcome upon a showing of substantial need. See, e.g., Textron, 157 F.R.D. at 522. Other familiar privileges are described as qualified rather than absolute. See, e.g., Nixon, 418 U.S. at 705-706, 94 S.Ct. at 3106-3107 (<HOLDING>); In re Certain Complaints Under Investigation,
recognizing privilege recognizing qualified privilege for confidential presidential communications recognizing a qualified privilege for confidential sources in a libel suit holding that communications among judges related to official judicial business are protected by a qualified privilege recognizing qualified privilege protecting confidential communications among judges and their staffs in the performance of their judicial duties