In finding that Yum had demonstrated that the documents really were prepared in anticipation of litigation, despite the lack of any "overt" indication that the IRS would pursue litigation against Yum, the appeals court enumerated four key facts that Yum had established: " a specific transaction that could precipitate litigation,  the specific legal controversy that would be at issue in the litigation,  the opposing party's opportunity to discover the facts that would give rise to the litigation, and  the opposing party's general inclination to purse this sort of litigation.
The appeals court also explained that the original affidavits provided to the magistrate judge were conclusory assertions that the documents were created in anticipation of litigation but Yum was permitted to supplement the record and provide more concrete and detailed support for its work-product claim.
, in this case, is a thin spicy Thai soup which makes a really good winter warmer.
yai, as do all the Friend salads, utilizes fresh, crisp romaine as its solo lettuce.
Cheryl Bachelder, who has been president of KFC's domestic operations since early 2001, stepped down after more than two years in the post to pursue unspecified other interests, Yum
In September 2011, Yum
sold its Long John Silver's and A&W Restaurant chains.
Cotton Candy," the newest flavor from Bubble Yum
Bubble Gum, will arrive on retail shelves in October.