In Chevron Corp. v. Weinberg Group, Misc. Action No. 11-409 (D.D.C. Sept. 26, 2012), the court fashioned a process for the production of redacted work product designed to minimize the issues in dispute while expediting production and resolution of bona fide disputes.  Chevron sought discovery of documents from Weinberg, an expert retained in an underlying action in Ecuador which resulted in a multi-billion judgment against Chevron.  Chevron sought the documents for use in an action in New York that challenged the judgment on grounds of fraud.  Weinberg asserted work product protection over thousands of pages of documents, and submitted a privilege log that the court found to be woefully inadequate.  The court held that Chevron had demonstrated substantial need for the documents and there was no means to secure the information other than seeing the documents in Weinberg’s possession.  Therefore, Weinberg was required to produce fact work product, but would be allowed to redact opinion work product prior to production.  To streamline the process, minimize disputes, and expedite production, the court instructed Weinberg to:  (1) make a rolling production of redacted documents at the rate of 100 documents per day until completed; and (2) at the time of each production, submit a document that explains, as to each redaction, why it qualifies for opinion work product protection.  The court explained that it hoped that by its process: Weinberg would see the wisdom of abandoning any claim of privilege as to meaningless documents that might technically be privileged but which are insignificant (and offered to enter an order pursuant to Rule 502(d) of the Federal Rules of Evidence “that would alleviate any concern it has about such a disclosure constituting a waiver in any other state or federal proceeding”), while Chevron would see from the gist of the document that the redacted portion is insignificant, and conclude that further litigation is unnecessary.