Disclosure Statements “At Minimum” Ordinary Work Product; United States District Court for the Eastern District of Texas, Sherman Division, No. 4:16-CV-00395, U.S. ex rel. Michael J. Fisher, Keith Franklin, Chezza Hartfield, and Regina McPhaul v. JPMorgan Chase Bank N.A.

The district court denied the defendant’s motion to compel discovery of the relators’ disclosure statements to the government, finding that the defendant had not demonstrated the information in the statements was necessary to test the relators’ qualification as original sources or to test materiality.