Henry Smith is a self-employed electrician who works in San Francisco, California. On July 10, 2011, Henry was riding a MUNI train to a Giants game at AT&T Park when an automobile driven by Reuben James ran a traffic light at an intersection and collided with the MUNI train. Henry suffers severe personal injuries and is unable to work for approximately four months after the accident. Henry files suit against Reuben James and claim a loss of earnings as part of his damages in the case. Counsel for Defendant Reuben James serves Henry's attorney with a Request for Production of Documents including the following Request: "Please produce a copy of your state and federal income tax returns from July 1, 2007, to the present time."

Henry's attorney responds to the Request for Production through the following Objection: "Objection, income federal and income tax returns are privileged information. Said request is further objected to because the plaintiff has produced all available documents supporting his claims of income loss." Henry (Plaintiff) also argues that he has produced invoices, balance sheets, canceled checks, and information regarding customer accounts to document his claimed income loss as a self-employed electrician. Reuben's attorneys argue that the production of Henry's income tax returns is the only reliable documentation of his income loss, citing Newsom v. City of Oakland (1973) 37 Cal. App. 3d 1050 in support of his argument. Defendant Reuben's attorneys send a "meet and confer" letter to the attorneys for Plaintiff Henry in which they threaten to file a Motion to Compel with the court unless the income tax returns are produced as requested.

Would you please draft an inter-office memorandum responding to the arguments made by Defendant Reuben? It predicts the likely outcome of anyMotion to Compel.

Also, include the second part opening paragraph of a Memorandum of Points and Authorities in opposition to the anticipated Motion to Compel to be filed by the attorneys for Defendant Reuben.