- 7 - a substantial need for the information in the documents to prove that purpose. The L.L.C. memorandum recognizes that substantial need is one of the elements that a party must show to overcome the work product privilege. Apart from arguing the availability of substantially equivalent information from other sources, the L.L.C. memorandum does not argue that respondent lacks a substantial need for the information in the documents. Putting aside other sources, we think that respondent has shown a substantial need for the information in the documents, and we so find. As to the availability to respondent of substantial equivalents to the documents, we think that respondent’s efforts to obtain information about the two meetings from Messrs. Hananel and Robinson show the futility of relying on memory to describe the particulars, indeed, even the occurrence, of two relatively brief meetings that occurred more than 8 years ago. Petitioner and the L.L.C. do not suggest that, other than the memories of the participants, there is any substantial equivalent to the documents from which the happenings at the two meetings can be established. We agree with respondent that there is no other way for him to obtain the information contained in the documents other than to examine them. Respondent has made an adequate showing to overcome the privilege resulting from the work product doctrine, as claimed by petitioner and the L.L.C.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008