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Cardi B and Taylor Swift get into a car crash while coming back from a Call of Duty tournament. Cardi B's car is totaled and she injures her shoulder and ankle. On a stretcher going into an ambulance, she screams, "You should have looked both ways before crossing me!" at Swift. Cardi B threatens to sue. Swift's lawyer interviews witnesses to the accident and concludes it's likely that Swift ran a red light right before the accident. Later Cardi B tweets out that her lawyers are currently forum shopping to find the best jurisdiction to sue in. Subsequently, Cardi B does file suit and seeks to compel production of Swift's lawyer's memorandum assessing the witness interviews. Was the memorandum prepared "in anticipation of litigation?"A.Yes under the specific claim test.B.Yes under the primary purpose test.C.No.D.Yes under both the specific claim test and primary purpose test.
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