or obtained because of the prospect of litigation. But the converse of this is that even though litigation is already in prospect, there is no work product immunity for documents prepared in the regular course of business rather than for purposes of litigation. Bieter Co. v. Blomquist, 156 F.R.D. 173, 180 (D.Minn.1994) (quotation omitted). Litigation was in prospect or ongoing when the billing documents were prepared, so the issue becomes which parts of them were prepared in the regular course of business and which parts were prepared for the purpose of litigation. Only “opinions, conclusions, legal theories, or mental impressions of counsel” qualify as work product. Dennie, 387 N.W.2d at 406. Generally, billing records do not fall into this category. See Bieter, 156 F.R.D. at 180 (<HOLDING>). However, work descriptions that contain
holding that municipal court records were admissible under  official records or public documents  exception holding that  14501c1 preempted statelaw claims of fraudulent and negligent misrepresentation and money had and received related to billing practices of motor carrier of property holding that the disclosure of billing invoices and cost reports were neither allegations of fraud nor fraudulent transactions holding that records relating to a student court were not education records holding that billing records were discoverable and citing rayman v am charter fed sav  loan assn 148 frd 647 660 dneb1993 attorney billing statements not subject to workproduct protection