When confronted with a Subpoena or Request for Discovery, the party must consider the use of the materials in the future at trial and the cost in defending the right of a work product defense. As is required by the Federal and State Rules of Civil Procedure, at a minimum, a party must disclose through a privilege log the material that is requested. Should you find yourself with a question as to whether to produce materials, please feel free to contact any of the attorneys at Collins & Lacy, P.C.