as codified in Fed.R.Civ.P. 26(bX3), *468 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