Elaine had worked for Company for 30 years as an administrative assistant. Elaine had a new manager who thought Elaine was too old to do her job and wanted to bring in younger people to work for Company. Manager complained to other employees that Elaine was too slow and old to do the job. Manager would berate and criticize Elaine in front of her coworkers. Elaine complained to the H.R. department of Company. When Manager found out that Elaine had made a complaint against her to H.R., Manager fired Elaine. Elaine filed a lawsuit against Company in a federal district court alleging violations of the Federal Employment Act and the Federal Discrimination Act. During discovery, Elaine learned that Manager had previously engaged in the same type of treatment to another older employee and that Manager had been disciplined by Company as a result. Elaine seeks to obtain Manager's disciplinary records from Company. Under the Federal Rules of Civil Procedure, will Elaine be able to obtain these records