Metalco operates smelters used in the production of iron, copper, and lead. The company learns that a TV reporter is producing an exposé of the company’s alleged violations of environmental laws. Belinda Burke, Metalco’s general counsel, hires an environmental consulting firm to perform an investigation of the smelting operations. Her purpose is to have data on hand to use in rebutting the story when it airs. Unfortunately, the consultant concludes that the journalist’s allegations are substantially accurate. For obvious reasons, Burke decides not use the report. Within weeks the company is sued by an environmental organization. The plaintiff learns about report and files a discovery demand that Burke turn it over. Must she do so?