Mаthieu wаs seriоusly injured in аn accident at Marrоd’s Department Stоre. In anticipation of possible litigation, the attorney for Marrod’s Department Store interviewed Cullin, a customer who was the only witness to the accident. The attorney prepared a written account of Cullin’s statement, and Cullin signed it.One year later, Mathieu filed a personal injury lawsuit against Marrod’s Department Store. In preparing the case, Mathieu’s lawyer identified and interviewed Cullin who had witnessed the accident. Unfortunately, Cullin retained little memory of the accident’s details. Mathieu’s lawyer then served a formal discovery request for any documents memorializing Cullin’s prior statements. The attorney for Marrod’s Department Store refused to produce the written account, memorializing Culin’s prior statements. The attorney for Marrod’s Department Store refused to produce the written account, citing the attorney-client privilege and the work-product doctrine.Is the court likely to require Marrod’s Department Store’s attorney to produce the written account?