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seeking disclosure conclusively demonstrates the absolute impossibility of securingsimilar information from other sources.” 12The Illinois Supreme Court also agrees with the United States Supreme Court that: “notesregarding oral statements of witnesses, whether in the form of attorney’s mentalimpressions or memoranda, necessarily reveal in varying degrees the attorney’s mentalprocesses in evaluating the communications.” 13The Consolidation Coal decision alsowas based on the fact that “notes of conversation with witnesses are so much a productof the lawyer’s thinking and so little probative of the witnesses’ actual words” 14 , findingthe attorney’s summaries of witness and defendant’s employee interviews protected bythe Attorney Work Product Doctrine. 15The Illinois Supreme Court also has held that“verbatim statements of [a] witness” are not protected the way summaries are, since thesummaries reveal “a particular marshalling of the evidentiary facts” and “reveal theattorney’s mental processes in shaping his theory of his client’s cause.” 16The elements required to establish that a communication is within the attorney-clientprivilege are well settled:(1) Where legal advice of any kind is sought (2) from a professional legaladviser in his capacity as such, (3) the communications relating to thatpurpose, (4) made in confidence (5) by the client, (6) are at his instance12 Id.13 Id. (citing Upjohn, 449 U.S. at 399-400)).14 Id. (citing In re Grand Jury Investigation, 412 F.Supp. 943, 949 (E.D. Pa. 1976))15 Id. at 254.16 Monier v. Chamberlain, 221 N.E.2d 410, 418 (Ill. 1966).11