OPINION
FABE, Justice.
I. INTRODUCTION
Daniel DeNardo filed this lawsuit against his former coworker Joy Bax alleging defamation. DeNardo based his claim on comments made by Bax to coworkers that she was "worried that [DeNardo] was 'stalking' [her]." The superior court granted summary judgment to Bax on the grounds that her statements were privileged as statements of concern about personal safety in the workplace and that DeNardo had failed to provide [675]*675evidence that Bax abused the privilege. De-Nardo appeals, conceding that Bax's comments were privileged but arguing that there were sufficient factual issues surrounding the question of abuse that the issue should have been submitted to a jury rather than decided on summary judgment. Because the superi- or court correctly determined that DeNardo failed to produce sufficient evidence that Bax acted with knowledge or reckless disregard as to the falsity of her statements (thereby abusing the privilege) we affirm.
II. FACTS AND PROCEEDINGS
A. Facts
Daniel DeNardo and Joy Bax were formerly coworkers at Alaska Newspapers, Inc. (ANI). When DeNardo was terminated from ANI, he filed a lawsuit in federal court against his former employer, its parent company Calista Corporation, and several former coworkers, including Bax. During a videotaped deposition in that case attended by Bax, DeNardo was asked by Joan Rohlf, attorney for defendants, if he was currently in possession of any weapons. DeNardo refused to answer.
Based on DeNardo's refusal to answer whether he was in possession of a weapon at the deposition, Rohlf moved for a protective order, requesting permission to conduct the remainder of DeNardo's deposition at the federal courthouse, where DeNardo would have to undergo a security screening. Attached to the motion were affidavits from Rohlf and three of the codefendants present at the deposition, including Bax.
Bax's affidavit in support of the motion stated:
I attended Mr. DeNardo's deposition on March 9, 2001. I was extremely concerned when Mr. DeNardo refused to answer whether he had brought a weapon to the deposition. When we worked together at ANI, there were several occasions when Mr. DeNardo followed me in his vehicle. I was worried that he was "stalking" me. I have expressed concern about this to Holly Parsons and other defendants in this action, as well as to Ms. Rohlf. Annie Harris has expressed concern to me that Mr. De-Nardo was loitering around her personal residence last fall. Holly Parsons has expressed similar concerns. Based on my observations and knowledge of Mr. DeNar-do while we worked together at ANI, and based on these incidents, I am very concerned about my personal safety in Mr. DeNardo's presence.
B. Proceedings
In response to this affidavit, DeNardo filed a new lawsuit in superior court alleging that Bax maliciously made statements to coworkers, Holly Parsons and Annie Harris, that DeNardo was stalking Bax. DeNardo claimed that Bax's statements were "maliciously made," "false, defamatory, spurious, and libelous," and "were understood by others as referring to DeNardo and charging DeNardo with the corrupt and dishonorable conduct of stalking which is criminal conduct in the State of Alaska." In the complaint, DeNardo denied stalking or following Bax.
During the course of discovery, DeNardo filed several interrogatories and requests for production. Bax moved for a protective order asking that the superior court limit DeNardo's access to certain witnesses and preclude discovery irrelevant to the defamation suit. The superior court granted this motion, allowing DeNardo to depose Bax's former employers and ex-husband only if DeNardo provided proper notice to Bax's counsel and each deponent and only if Bax's counsel was present at the depositions. The superior court's order required all telephone conversations between DeNardo and Bax's ex-husband, coworkers, or supervisors to be conducted as conference calls in which Bax's counsel could participate. The superi- or court limited the seope of these depositions and phone calls as follows: "DeNardo may ask whether: (1) Bax ever informed the witnesses whether she had ever been stalked ... followed, or harassed by Mr. DeNardo; (2) what such stalking or harassment reportedly consisted of; and (8) the basis for Bax's stated belief" The superior court also permitted DeNardo to ask whether Bax had informed witnesses that DeNar-do had "loitered at residences." The order specified that DeNardo was not allowed to [676]*676ask witnesses about Bax's personal life or social relationships and was not permitted to question the witnesses about information irrelevant to the defamation claim. The court noted that Bax was not required to provide DeNardo with her current address as long as she was represented by counsel. DeNardo also was not allowed to contact Bax's twelve-year-old daughter. DeNardo moved for a reconsideration of the court's protective order, but that motion was denied.
Bax moved for summary judgment, arguing that her statements were not false because they were based on her own observations and subjective concern that DeNardo was following and possibly stalking her. She also asserted that the statements in her affidavit filed in the federal court case were absolutely privileged and that the conversations she had with coworkers that were referenced in her affidavit were conditionally privileged because coworkers share a common interest in workplace safety.
DeNardo opposed Bax's motion, denying that he ever stalked Bax and claiming that Bax's allegation that DeNardo stalked her was defamation per se. He further argued that "(elven assuming a conditional privilege, it is a jury issue whether the privilege is lost from abuse upon a showing of reckless disregard, deliberate indifference, or actual malice."
The superior court granted Bax's summary judgment motion, finding that Bax's statements in the sworn affidavit filed in the federal court case were "completely" privileged and that the statements made by Bax to coworkers, memorialized in the affidavit, were protected by a conditional privilege, the abuse of which DeNardo had failed to establish. Although the superior court held that Bax was not entitled to summary judgment on the questions whether her statements were false or negligently made or whether Bax's statements were defamation per se, the superior court found that "nothing has been submitted ... to support a finding that Mr. DeNardo has shown that Ms. Bax in making these statements was making them with knowledge or reckless disregard as to their apparent falsity."
On appeal, DeNardo argues that even if Bax's comments were privileged, there are disputed facts as to whether the privilege was abused. Therefore, he argues, his claims should have been submitted to a jury rather than disposed of on summary judgment. He further challenges the superior court's protective order as a violation of the work product privilege and his right to discovery.1
III DISCUSSION
A. Standard of Review
The superior court has broad discretion to determine the scope and extent of discovery and to craft protective orders.2 A court's protective order restricting discovery will not be overruled absent abuse of discretion.3
We review a grant of summary judgment de novo, affirming if the record contains no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.4 When considering a motion for summary judgment, all reasonable inferences of fact from the proffered evidence [677]*677must be drawn against the moving party and in favor of the non-moving party.5
Whether a statement is defamatory 6 and whether a statement is afforded privilege7 are questions of law. If the relevant facts of the case are disputed, a jury must determine if a conditional privilege has been abused.8 When considering legal issues of first impression, such as whether a previously unrecognized privilege applies, we will adopt the rule of law that is most persuasive in light of precedent, reason, and policy.9
B. The Superior Court's Protective Order Did Not Inappropriately Restrict Discovery.
As a threshold matter, we address DeNardo's appeal of the superior court's decision granting Bax's motion for a protective order. Under Alaska Civil Rule 26(b)(1) a party "may obtain discovery regarding any matter, not privileged which is relevant to the subject matter involved in the pending action." But the court can, with good cause, enter any protective order that "justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense."10 Civil Rule 26(c) allows the court to deny discovery, to designate certain terms and conditions for discovery, to regulate the method of discovery, and to limit the scope of discovery.11
1. The superior court's protective order struck a reasonable balance between DeNardo's right to discovery and Bax's right to be protected from unduly intrusive discovery.
The superior court did not abuse its discretion when it limited DeNardo's discovery to facts relevant to his defamation claim. De-Nardo's defamation claim centered on whether Bax made defamatory statements to her coworkers that she was worried DeNardo was stalking her and whether these statements were made with malice. The superior court's order confining discovery to whether Bax ever informed witnesses that she had been stalked or harassed by DeNardo, what such stalking or harassment consisted of, and the basis for Bax's stated belief, struck a reasonable balance between DeNardo's right to discovery on his claim, and Bax's right to be protected from "annoyance, embarrassment, oppression, or undue burden or expense." 12
The superior court's order that DeNardo was not permitted to elicit information about Bax's personal life or social relationships and was not entitled to Bax's address also achieved a reasonable balance. In seeking a protective order, Bax informed the trial court that she was "gravely concerned about disclosing her current address to Mr. DeNardo for the very reason that has become the subject of this lawsuit: Mr. DeNardo followed her on several occasions in the past, eavesdropped on her private conversations at work, and reportedly has shown up unexpectedly near the residences of at least two of their former female co-workers." Given the nature of the controversy-a defamation claim based on Bax's expression that she was worried DeNardo was stalking her, which was only brought to DeNardo's attention in an affidavit in support of a motion seeking a secure location to conduct a deposition for fear that DeNardo was carrying a weapon-the court was well within the bounds of its discretion in limiting access to this personal and only tangentially relevant information. Because of the nature of the dispute, the court also reasonably prohibited DeNardo from contacting Bax's young daughter. Moreover, there is no indication from the record that Bax's daughter would be likely to provide any relevant evidence.
[678]*678DeNardo's arguments that the court's protective order "restricted the presentation of facts on summary judgment," and that "Bax's family members, former husband, former employers, and neighbors basically were ruled out of bounds" are unpersuasive in light of both the reasonableness of the superior court's order and the fact that DeNardo made no effort to depose any witnesses to support his claim within the sensible parameters drawn by the superior court.
We therefore conclude that the superior court did not abuse its discretion when it crafted a protective order designed to "balance Mr. DeNardo's right to the discovery of relevant information against Ms. Bax's right to privacy and her fears for the personal safety of herself and her daughter."
2. The superior court's protective order did not violate the attorney work product privilege.
DeNardo also argues that the superi- or court's order allowing DeNardo to interview and depose witnesses only in the presence of Bax's counsel violated the work product privilege. He alleges that the protective order "affected [his] interview strategy, the witness' testimony, and allowed Bax to be privy to the content of [his] notes and fact collection." In so arguing, DeNardo misconstrues the work product privilege.
The attorney work product privilege is designed to protect the mental impressions, conclusions, and opinions of an attorney in the preparation of materials for use in litigation.13 As set forth in Langdon v. Champion, in order for materials to qualify for work product protection, the material involved must be: (1) a document or other tangible thing, (2) prepared in anticipation of litigation or for trial, and (8) prepared by or for the opposing party's attorney or representative.14
Bax did not seek discovery of any documents or tangible items prepared by De-Nardo for use in this litigation that could potentially be subject to the work product privilege, nor did the protective order compel production of or even address any such materials. Additionally, the mere presence of Bax's counsel at depositions and in witness interviews would not violate the purposes of the work product privilege. Bax's counsel, through her presence, would not have access to DeNardo's mental impressions, conclusions, and opinions. The protective order therefore did not violate the work product privilege.
C. Summary Judgment Was Properly Granted Because Bax's Statements to Coworkers Were Privileged and DeNardo Presented No Evidence that the Privilege Was Abused.
In order for a defamation claim to succeed, a plaintiff must establish:
(1) a false and defamatory statement; (2) an unprivileged publication to a third party; (8) fault amounting at least to negli-genee; and (4) the existence of either "per se" actionability or special harm.[15]
The superior court determined that DeNardo failed to establish the second element, an unprivileged communication, and granted summary judgment in favor of Bax. The superior court reasoned that the statements Bax made to coworkers that "she felt she was being stalked" were conditionally privileged as statements of concern about personal safety in the workplace.
DeNardo does not challenge the superior court's determination that Bax's statements were privileged. Rather, he raises a claim that he was entitled to a jury trial on whether Bax abused the conditional privilege. But because we have never directly addressed the question whether a conditional privilege exists with respect to statements among coworkers about personal safety in the workplace, we first recognize that such a privilege applies.
[679]*679In the past, "we have recognized a conditional privilege based on a joint business interest or an employer/employee relationship when a statement is made 'for the protection of a lawful business, professional, property or other pecuniary interest' 16 And in Taranto v. North Slope Borough, we found that "speech on matters of public safety is privileged." 17 While communications among coworkers concerning personal safety in the workplace do not fall squarely within the ambit of either of these recognized privileges, our previous acknowledgment of the importance of protecting speech regarding business interests and public health and safety lends support to recognition of a privilege in this case.
We will acknowledge a conditional privilege when a person "having a common interest in a particular subject matter believes that there is information that another sharing the common interest is entitled to know."18 According to the Restatement (Second) of Torts, "[aln occasion makes a publication conditionally privileged if the circumstances induce a correct or reasonable belief that (a) there is information that af-feets a sufficiently important interest of the publisher, and (b) the recipient's knowledge of the defamatory matter will be of service in the lawful protection of the interest.19 Where, as here, a worker reveals to coworkers that she is concerned that another coworker might be stalking her, a sufficiently important interest to the statement's publisher, her personal safety, is at stake. Furthermore, by alerting coworkers to her fears, Bax protected her interest in personal safety by attuning coworkers to the possibility that she was the victim of dangerous behavior. Recognition of a privilege under these circumstances is necessary in order to facilitate an environment in which employees feel safe while performing their duties.
At the summary judgment stage, it was Bax's initial burden to establish that she was entitled to prevail as a matter of law, by demonstrating that a conditional privilege applies and that she did not abuse the applicable conditional privilege. In the trial court, Bax satisfied this initial burden by relying on her federal court affidavit as evidence that she did not abuse the privilege, arguing in her briefing to the trial court:
In her motion, Ms. Bax presented evidence that she did not abuse the privilege. Ms. Bax's affidavit states: "When we [Ms. Bax and Mr. DeNardo]l worked together at ANI [Alaska Newspapers, Inc.] there were several occasions when Mr. DeNardo followed me in his vehicle. I was worried that he was 'stalking' me."... Therefore, the proof that Ms. Bax actually saw Mr. DeNardo (or at least thought she did) is her affidavit itself. Ms. Bax's sworn affidavit shows that her statements were not made knowing they were false, and that her statements were not made with a reckless disregard for the truth.
Once Bax established a prima facie case that a conditional privilege applied and that she did not abuse the privilege, the burden shifted to DeNardo to show that the privilege had been abused.20 We have established that a conditional privilege may be abused:
(1) when there is malice-the publisher had knowledge or reckless disregard as to the falsity of the defamatory matter;
(2) because the defamatory matter is published for some purpose other than that for which the particular privilege is given;
(3) because the publication is made to some person not reasonably believed to be necessary for the accomplishment of the purpose of the particular privilege; or
(4) because the publication includes defamatory matter not reasonably believed to [680]*680be necessary to accomplish the purpose for which the occasion is privileged.[21]
Before the superior court, De-Nardo contended that Bax abused the conditional privilege because she acted with malice: knowledge or reckless disregard as to the falsity of her statements. Because the actual malice test for determining abuse of a conditional privilege is subjective, at the summary judgment stage the court must determine "whether there is a genuine issue of material fact on whether [the defendant] entertained serious doubts as to the truth of the statements."22 We note that the false and defamatory comment that Bax allegedly made was that Bax was worried that DeNar-do was stalking her and not that he was in fact stalking her. On summary judgment, DeNardo therefore has the burden of raising a material issue of fact on the question whether Bax entertained serious doubts about the truth of her statement that she was subjectively worried DeNardo was stalking her.
In support of DeNardo's claim that Bax's statement was made with malice, DeNardo essentially makes three arguments: (1) since Bax did not publish her statement of concern widely enough, she was not actually worried that DeNardo was stalking her; (2) Bax had a motive to lie because she and DeNardo had a workplace rivalry, which resulted in De-Nardo naming Bax as a defendant in his federal lawsuit against his employer; and (8) during the intermission of DeNardo's deposition in the federal lawsuit, Bax shared lunch with DeNardo, Parsons, and Harris, and "[nJobody displayed any fear and nobody objected." Even drawing all reasonable inferences in favor of DeNardo as the non-moving party, these allegations fail to raise a genuine issue of material fact on the question whether Bax entertained serious doubts as to the truth of her statement that she subjectively believed DeNardo was stalking her.
On the issue of the narrow scope of publication, DeNardo noted in his opposition to Bax's summary judgment motion that Bax only spoke to "sales manager Brandy Johnson, and co-workers Holly Parsons and Annie Harris. Bax never told her husband, children, family, neighbors, Calista Corporation management, Alaska Newspapers Inc. management, or any governmental authority about plaintiffs stalking!" He also noted that "Lolne day Bax saw [DeNardo] entering the Fred Meyer on Dimond after work. She never reported [DeNardo] was stalking her."
DeNardo does not meet his burden by pointing to the limited seope of Bax's publication. As DeNardo concedes, Bax expressed her concerns solely to her coworkers-those who knew DeNardo and were in the best position to observe the interaction between Bax and DeNardo in the workplace on a daily basis. It would not be reasonable to infer that Bax had serious doubts that her statements were true simply because she only discussed her concerns with those most familiar with her situation and those best able to assist her if DeNardo, a coworker, turned out to in fact be stalking her.
Moreover, excessive publication to persons not reasonably believed to be necessary for the accomplishment of the purpose of the privilege would constitute abuse of the privilege.23 That Bax limited the publication of her statement to two coworkers and her supervisor-those most suited to respond if Bax's subjective fear that DeNardo was stalking her proved true-supports the conclusion that her statement was well within the bounds of the common interest privilege in workplace safety, and not that Bax doubted the truth of her statements. In fact, the seope of Bax's publication appears to have been so narrow that DeNardo did not even learn about Bax's concern until he read her affidavit in the federal lawsuit when Bax's attorney, for fear that DeNardo was carrying a weapon, moved to relocate his deposition to federal court.
[681]*681Furthermore, DeNardo had the opportunity to question witnesses about the basis for Bax's belief that DeNardo was stalking her in order to bolster his claim that she entertained doubt as to the truth of her statements, but he declined to take advantage of that opportunity when he failed to depose any witnesses. The mere suggestion that Bax would have told her husband, children, family, friends, neighbors, etc., had she really believed DeNardo was stalking her is insufficient to raise a genuine issue of material fact that she entertained serious doubts that she was worried DeNardo was stalking her.
DeNardo points to evidence that Bax had a motive to defame him because she coveted his customer lists and commissions and because he filed an evaluation and notice of discrimination of a hostile workplace naming Bax as one of the perpetrators. DeNar-do also notes that he named Bax as a plaintiff in the federal lawsuit filed against his former employers. Affidavits attached to DeNardo's opposition to Bax's summary judgment motion could support an inference that there was some ill will between DeNardo and Bax when they were coworkers at ANI. For example, incorporated into DeNardo's brief were interrogatories of Calista Corporation and ANI from the federal lawsuit. When asked about oral or written complaints about DeNardo, Calista Corporation and ANI responded:
On a few occasions, Holly Parsons and Joy Bax had disputes with plaintiff [DeNardo] regarding who was entitled to commissions on ads which were brought to the attention of Brandy Johnson and/or Chris Casati. Holly Parsons and Joy Bax also discussed with Brandy Johnson and/or Chris Casati their concerns about plaintiffs unilateral declaration that certain sales prospects "belonged" to plaintiff, and concerns that plaintiff attempted to take over sales prospects that they were already pursuing. Joy Bax expressed concern to Brandy Johnson that plaintiff seemed to listen in on her telephone conversations, and listed prospects on his "cold call" list the week after Ms. Bax had had those prospects on her "cold call" list.
But evidence of ill will alone is not sufficient to establish abuse of the privilege. According to the Restatement (Second) of Torts § 608 emt. a (1977):
[A] publication of defamatory matter upon an occasion giving rise to a privilege, if made solely from spite or ill will, is an abuse and not a use of the privilege. However, if the publication is made for the purpose of protecting the interest in question, the fact that the publication is inspired in part by resentment or indignation at the supposed misconduct of the person defamed does not constitute an abuse of the privilege.
(Emphasis added.) In most jurisdictions, evidence that a defendant disliked a plaintiff is insufficient to establish abuse of the privilege.24 Instead, "ilt must be shown that the improper motive was predominant." 25 For example, the United States Court of Appeals for the District of Columbia has explained that
the mere existence of ill will on the part of the publisher toward the subject of the publication does not defeat the publisher's privilege if the privilege is otherwise established by the occasion and a proper purpose. Rather, the court looks to the primary motive by which the defendant is apparently inspired; and, the fact that he feels resentment and indignation towards the plaintiff and enjoys defaming him will not forfeit the privilege so long as the primary purpose is to further the interest which is entitled to protection.[26]
Here DeNardo alleges that Bax harbored ill will toward him because she competed with him for customers and commissions when they were employees at ANI and be-
[682]*682cause he implicated her in a workplace discrimination claim at both ANI and in federal court. But evidence that Bax might have disliked DeNardo does not cast doubt upon her statement that she feared DeNardo was stalking her. DeNardo even concedes that he saw Bax in the parking lot of Fred Meyer.27 His allegations of animosity between himself and Bax do not even speak to the question whether she might have actually felt fear when she encountered him. He therefore did not raise a question of fact that Bax's statement was made "solely from spite or ill will.28
It bears repeating that DeNardo's claim is based on a comment that Bax made in an affidavit in an unrelated federal case which was filed because DeNardo refused to answer whether he was carrying a weapon in a deposition. Bax informed the court:
When we worked together at ANI, there were several occasions when Mr. DeNardo followed me in his vehicle. I was worried that he was "stalking" me. I have expressed concern about this to Holly Parsons and other defendants in this action, as well as to Ms. Rohlf, Annie Harris has expressed concern to me that Mr. DeNar-do was loitering around her personal residence last fall. Holly Parsons has expressed similar concerns. Based on my observations and knowledge of Mr. DeNar-do while we worked together at ANI, and based on these incidents, I am very concerned about my personal safety in Mr. DeNardo's presence.
Bax's publication was made "for the purpose of protecting the interest in question," workplace safety, and therefore the fact that the publication might have been "inspired in part by resentment or indignation at the supposed misconduct of [DeNardo] does not constitute an abuse of the privilege."29
Finally, DeNardo does not meet his burden when he notes that during the intermission of DeNardo's deposition in the federal lawsuit, Bax shared lunch with DeNardo, Parsons and Harris, and "[njobody displayed any fear and nobody objected." The fact that DeNardo and Bax publicly ate lunch together during an intermission from his deposition and DeNardo did not perceive Bax display any fear does nothing to further his argument that she entertained serious doubts as to the truth of the statements she made to coworkers when she and DeNardo were both employed at ANL.
While DeNardo arguably set forth sufficient evidence to establish that Bax disliked him, he set forth no evidence to establish that Bax "entertained serious doubts as to the truth of the statements."30 Because De-Nardo has failed to meet his burden, we affirm the superior court's decision to grant summary judgment to Bax.
IV. CONCLUSION
For the foregoing reasons, we conclude that the superior court's protective order was not an abuse of discretion. Because Bax's statement that she feared DeNardo was stalking her was privileged as a statement of concern about personal safety in the workplace, and because DeNardo has not raised a genuine issue of material fact with respect to abuse of the privilege, we also AFFIRM the superior court's grant of summary judgment to Bax.