Aplaintiff filed a negligence action against a defendant in federal district court after a two-car accident. the plaintiff's attorney created a list of everyone he could identify who observed the accident or otherwise had information relevant to the accident. the list includes one eyewitness whom the plaintiff's attorney was able to identify only through the expenditure of several thousand dollars in investigation costs. the defendant served the following interrogatory on the plaintiff: " state the name of each person of whom you are aware who may know or have information relevant to this action."

must the plaintiff provide the defendant with the names of all of the people on the plaintiff's attorney's list?

a. no, because the names on the list are protected from discovery under the work product doctrine.
b. no as to the name of the eyewitness found through the plaintiff's investigation efforts, but yes as to the other names on the list.
c. yes, because, whil the names are subject to qualified immunity from discovery under the work product doctrine, the defendant will be able to show sufficient need to obtain a court order requiring the names' disclosure.
d. yes, because the names are relevant to the claims and defenses of the parties, and they do not constitute work product.