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A plaintiff serves a request for production seeking the defendant corporation's privileged internal investigation memo prepared by in-house counsel. The defendant objects on attorney-client privilege grounds. Plaintiff argues the memo also contains business advice. The court should:

Order production because in-house counsel communications are never privileged Order production only of business-advice portions, protecting legal-advice portions Deny production entirely because internal investigations are absolutely privileged Order production only if plaintiff shows substantial need

Correct Answer:

Order production only of business-advice portions, protecting legal-advice portions

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