Textron II ACC Amicus Brief filed in the First Circuit United States Court of Appeals. This brief argues: the work product doctrine historically protects analysis of litigation risks, as opposed to the facts underlying litigation; dual purpose documents inherently reflecting the anticipation of litigation are protected under Maine and established law; the exception for documents created in the ordinary course of business does not apply to the workpapers; the IRS is wrong to suggest that the substance of the workpapers is irrelevant to an analysis of the work product doctrine; the IRS's desire to simplify its investigations does not trump the work product doctrine. Additionally, an argument is made Textron did not waive work product protection.