ion between fact and opinion work product. Work product protection is limited to materials which are not intended to be used as evidence at trial. Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("when a party reasonably expects or intends to utilize an item before the court at trial, for impeachme

nt or otherwise, the video recording, document, exhibit, or other piece of evidence is fully discoverable and is not privileged work product."). In Northup, the court remarked that a litigant must decide whether the material is going to be used only for strategy and trial preparation purposes prior to t

vilege, and Epstein's attempt to invade that privilege to cure any purported defect in the defense's preparation of this case should be rejected. 50 Northup v. Acken, 865 So. 2d 1267, 1270 (Fla. 2004) ("Personal views of the attorneys as to how and when to present evidence, his evaluation of its relativ

nc. v. Hernandez, 638 So. 2d 988 (Fla. 3d DCA 1994). The work product privilege does not extend to materials intended for use as evidence at trial. Northup v. Acken, 865 So. 2d 1267 (Fla. 2004). Work product falls into two categories: 1) "fact" work product consisting of factual information pertaining