With no explanation, chose the best option from "A", "B", "C" or "D". has provided its witnesses to review in preparation for their depositions already have been produced to Plaintiffs or are otherwise publicly available. Plaintiffs cannot establish that have a “substantial need” to know which documents counsel used to prepare the witnesses, or that identification is “necessary in the interests of justice.” Indeed, in the few depositions to this point, Plaintiffs already have marked hundreds of produced 'documents as exhibits. There is no compelling need for them to see which documents defense counsel think are important. See Sporck, 759 F.2d at 318 (“Rule 612 should never implicate an attorney’s selection, in preparation for a witness’ deposition, of a group of documents that he believes critical to a case,”); see also Hanover Ins., 304 F.R.D. at 500 (<HOLDING>); af. Wright & Miller, Federal Practice &

A: recognizing plaintiff met this burden
B: holding that burden imposed to prove a level of trade adjustment was unreasonable because party could under no practical circumstances meet the burden
C: holding that an employee requesting unforeseeable medical leave is not required to even mention the fmla when requesting leave for a serious health condition
D: holding that requesting party had not met its burden to prove that justice required disclosure of compilation under rule 612
D.