does not extend to every document generated by an attorney, but the “key is whether or not the documents were prepared in anticipation of litigation.”) (citing Jordan v. United State y of Ms. Myrick’s declaration. Moreover,. the nature of the Hemisphere program, which clearly implicates controversial law-enforcement techniques and privacy rights as evidenced by this lawsuit, satisfies the Court that it is objectively reasonable for the government agencies involved to hold a subjective belief that litigation was and is a real possibility. The Court therefore concludes that the email at issue is protected by the work product doctrine because it was prepared in anticipation of litigation. See e.g., McKinley v. Board of Governors of Federal Reserve System, 647 F.3d 331, 341 (D.C.Cir.2011) (<HOLDING>). For all of these reasons, the email was
holding attorney workproduct was exempt from disclosure under foia exemption 5 even after the case was dismissed and litigation terminated by the ftc holding that letters addressing dispute that was subject of litigation and that were written in anticipation of litigation did not fall under business record exception under rule 8036 of the federal rules of evidence and noting that it is wellestablished that one who prepares a document in anticipation of litigation is not acting in the regular course of business holding that the workproduct doctrine was inapplicable where there was no indication a memorandum was prepared in anticipation of litigation holding that not all of claims file was prepared in anticipation of litigation and noting that the majority of cases that have dealt with the issue of whether investigative materials prepared by insurance claims adjusters is workproduct prepared in anticipation of litigation have held that since insurance companies have a routine duty to investigate accidents such materials are not prepared in anticipation of litigation holding that the work product doctrine applied to a document prepared in anticipation of litigation and was therefore protected from disclosure under foia exemption 5