pinion work product `enjoys a nearly absolute im- munity and can be discovered only in very rare and extraordinary circumstances' "). n414 FNI4. In Berkey Photo, Inc. A Eastman Kodak Co., 74 F.R.D. 6 (S.D.N.Y.1977), one of the first, and most often cited, cases to ad- dress the issue presented here, the court wa