courts have looked for various ways to harmonize the two rules. See Joint Eastern and Southern Dist. Asbros Litig., 119 F.R.D. 4 at 5, Redvanly . NYNEX Corp., 152 F.R.D. 460, 470 (S.D. .Y.1993). The process has pro- duced inconsistent results, with some courts concluding that work product mater- ials whi

he latter, the same as an agent, and the principal is liable for the acts of its agent within the scope of the agent's authority.”); United States v. NYNEX Corp., 788 EF. Supp. 16, 18 n.3 (D.D.C. 1992) (holding that “[a] corporation can of course be held criminally liable for the acts of its agents,” including