Tom and Marla are getting a divorce, and the disposition of their assets is a hotly contested issue.  Tom and his attorney sat down and created a spreadsheet that itemizes every band account, retirement account, investment account, insurance policy, and title to real property that Tom owns.

Marla's attorney files a request for production of documents specifically asking for documentation about Tom's assets.  Do Tom and his attorney have to provide opposing counsel with the spreadsheet?

A. yes, because a request for production of documents must be met with a comprehensive disclosure

B. yes, because it is better to provide a summary of assets rather than documents related to the assets themselves (such as copies of insurance policies or deeds)

C. no, because it is attorney-client work product

D. no, because Tom's financial assets are not relevant to their divorce proceedings