New Jersey Carpenters Pension Fund v. infoGROUP, Inc.,  C.A. 5334-VCN (August 16, 2012)

This decision clarifies that to have discovery of work product a party needs only show a "substantial need" and that it would be an "undue hardship" to get the information some other way.  Despite some contrary language in the famous Garner case, there is no requirement that you also show the information is sought in "good faith."