Privilege Log

In  a number of prior posts I have talked about the benefit of using Rule 1006 summaries.   In my opinion, these summaries could also be used to argue your case to make detailed factor charts on the Albright factors for custody or any of the other factor tests used in Mississippi.  The question then becomes, must they be disclosed in discovery.  I say no as they are attorney-work product.  The best way to handle the situation is to make a privilege log to disclose in discovery of what all you are claiming as attorney work product to provide in discovery.  If there is any question, the judge can sort it out.