Attorneys generally like to think of their work product as being sacrosanct and immune from discovery. Although the work-product doctrine, as codified in Mass. R. Civ. P. 26(b)(3), provides only qualified protection for materials prepared in anticipation of litigation or trial, there are relatively few decisions ordering the disclosure of bona fide work product. That is, in part, because courts have been instructed that protecting work product "enhance[s] the vitality of an adversary system of litigation by insulating counsel's work from intrusions, interferences, or borrowings by other parties."1