Julio, the insured, threatened to sue Chastity and her employer, Colossal Casualty, for bad faith in handling her claim. After learning of this threat, and while events were still fresh in her mind, Chastity drafted a memo for the claims file summarizing every action that might conceivably be used as evidence against her and explaining why her actions were valid. What argument could Chastity and her attorney use to keep this document in the file from being released to Julio's attorney as part of the discovery process?

$($Search Chapter $3).$

a$.$ Conflict of interests

b$.$ If Chastity shares the memo with her attorney, attorney$-$client privilege applies.

c$.$ If Chastity's attorney directed her to prepare the memo, it is protected because she was acting on the advice of counsel.

d$.$ The work product doctrine protects this memo because it was drafted in anticipation of litigation.