9 F.3d 681, 687 (1st Cir. 1997) ("the prevailing rule that disclosure to an adversary, real or potential, forfeits work product protection"); In re Steinhardt Partners, L.P., 9 F.3d 230, 235 (2nd Cir. 1993) ("voluntary disclosure of work product to an adversary waives the privilege as to other parties"); In re Chr

ot eiplicitly consensual."). See, e.g GAF Corp. t. East- man Kodak Co., 83 F.R.D. 46, 51-52 (D.C.N.Y.1979), abrogated on other grounds by In re Steinhardt Partners, 9 F.3d 230, 233 (2d Cir.1993) ("The majority rule provides that disclosure of the priv- ileged information by the party asserting the attorney wo