EXHIBIT K¶
401 EAST LAS OLAS BOULEVARD • SUITE 1200 • FORT LAUDERDALE, FL 33301-2211 • PH: 954.356.0011 • FAX 954.356.0022¶
Sigrid S. McCawley, Esq.
E-mail: smccawley@bsfllp.com¶
June 10, 2016¶
VIA E-MAIL¶
Laura A. Menninger, Esq.
HADDON, [REDACTED] AND [REDACTED], P.C.
150 East 10th Avenue
Denver, Colorado 80203
lmenninger@hmflaw.com¶
Re: [REDACTED] v. Maxwell
Case No. 15-cv-07433-RWS¶
Dear Ms. Menninger:¶
On behalf of the Plaintiff, [REDACTED], documents, [REDACTED]-stamped GIUFFRE005607 through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production. Certain of the documents within this production have been designated as CONFIDENTIAL in accordance with your proposed Protective Order. Please treat these documents accordingly.¶
This production consists solely of all data that is responsive to Defendant's various requests for production from [REDACTED] iCloud account.¶
Attached to this letter, please also find an updated privilege log.¶
If you have any questions concerning the foregoing, or if there are any issues with the media, please do not hesitate to contact me at (954) 356-0011.¶
Sincerely,¶
Sigrid S. McCawley¶
SSM:dk
Enclosures¶
From: Richards. Jason FL To: 6002a= Subject: RE: HI There Date: Wednesday, August 27, 2014 10:44:32 AM¶
Hi Jenna,¶
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information you are looking for because I am not able to release information (should there be any) from FBI records. You need to include as many details as possible so they can focus and narrow the search. Explain that you are looking for information related to your recovery as a victim of . The process may take some time but it is the appropriate method for you to obtain any possible records regarding your recovery. Hope this helps.¶
Best wishes,¶
Jason¶
Original Message¶
From: Sent: Wednesday, August 27, 2014 9:49 AM To: Richards, Jason R. Subject: Hi There¶
G'day Jason,¶
I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an era, just need a couple dates confirmed is all.¶
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept upside down looking through records and come up w nada. What was your acquaintance's name that took my statement about Is it possible that it wasn't Wilton Manors and maybe it was somewhere else?¶
I'm really racking my brain about this!! It would be a personal favor to me and I am so very much appreciative of anything you might know!!¶
Thanks a lot mate!!¶
Jenna¶
From: Richards, Jason R.
To: [REDACTED]
Subject: Re: Hi There
Date: Wednesday, August 27, 2014 10:50:27 AM¶
Feel free to reach out to me any time.
Take care.¶
Jason¶
----- Original Message -----¶
From: [REDACTED]
To: Richards, Jason R.
Sent: Wed Aug 27 10:46:50 2014
Subject: Re: Hi There¶
Thank you Jason. I hope all has been well for you and yours!¶
All the best, I won't bother you again.¶
Jenna¶
Sent from my iPhone¶
On Aug 27, 2014, at 10:44 AM, "Richards, Jason R." Jason.Richards2@ic.fbi.gov wrote:
¶
Hi Jenna,
¶
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information you are looking for because I am not able to release information (should there be any) from FBI records. You need to include as many details as possible so they can focus and narrow the search. Explain that you are looking for information related to your recovery as a victim of [REDACTED]. The process may take some time but it is the appropriate method for you to obtain any possible records regarding your recovery. Hope this helps.
¶
Best wishes,
¶
Jason
¶
-----Original Message-----
¶
From: [REDACTED]
¶
Sent: Wednesday, August 27, 2014 9:49 AM
¶
To: Richards, Jason R.
¶
Subject: Hi There
¶
G'day Jason,
¶
I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an era, just need a couple dates confirmed is all.
¶
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept upside down looking through records and come up w nada. What was your acquaintance's name that took my statement about [REDACTED]? Is it possible that it wasn't Wilton Manors and maybe it was somewhere else?
¶
¶Thanks a lot mate!! > > Jenna > > Sent from my iPhone From: To: Intim Richards21Mc Ibi aov Subject: Jane doe 102) Date: Tuesday, April 15, 20119:50:31 AM
Hi Jason,¶
Long time, no talk. I hope all has been well for you and yours!! I am now back in the USA, not too many people know about that and I'd like to keep it that way as my case against Jeffrey Epstein has intensified!! I am here to get this BS non- prosecution agreement thrown out and speaking w Judge Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI to assist our case further in proving how much pedophilia occurred by Jeffrey and the many other monsters he obliged w underage girls. If this is a possibility please let me know so I can give you Brad my attorney) his contact details. Many thanks for your time and I hope we should meet again.¶
Kin r, Phone 8¶
From: To: crinoline ovroreic Id aov Subject: re: Jeffrey Epstein Case Date: Wednesday, April 16. 2014 1:52:05 PM¶
Hi Christina,¶
I was wondering if you remember me from Sydney Consulate, I am a victim in the investigation from the Jeffrey Epstein case and was wondering if you could tell me if I would be able to get ahold of any of the pics and/or videos that the FBI might have confiscated from any of Epstein's residences? Also can I ask if you might have any of the flight logs that include my name in them to be sent to me as well. It's all for evidential purposes and would prove a many of things to help my case.¶
Kindes R ar s,¶
From: To: Subject: Date: statouthaaj@gmaigam on behalf of Sharon Rikard Re: Victims Refuse Silence Saturday. March 28, 2015 9:49:55 AM¶
Hi Virginia,¶
So sorry for the late response. Our organization currently works with survivors of sex trafficking provided continuing education, life skills and counseling. We will help with transportation and their basic necessities. Our ultimate goal is a home for domestic minor sex trafficking survivors.¶
Our contact information is:¶
rinorstofreedom corn¶
inforOdoorstofreedom.com¶
843-817-0740¶
ii going to forward your information to our Attorney Generals office as¶
Sazehn has compiled a list of organizations in our state of people/organizations an their involvement in helping survivors.¶
Thanks for all you are doing to help others!¶
Blessings,¶
Sharon Rikard¶
From: To: 81181201§21192110a8.208901.82M Subject: Victims Refuse Silence Date: Wednesday, Mardi 18, 2015 12:19:06 PM¶
141 Sharon,¶
This is Virginia, we spoke earlier and I just wanted to say thank you for your time and what your doing to help the victims in your area. The mentality has to be changed!! Good luck!!¶
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege Action | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 1 | 2/12/2015 6:14 | [REDACTED] | smccawley@bsfllp.com | Email chain with [REDACTED], [REDACTED] and Cassell re attorney impressions and legal advice relating to deposition testimony | AC Privilege and Work Product/joint defense/common interest | Withheld | 3 | msg | |
| 2 | 2/16/2015 1:05 | StanPottinger@aol.com | Smccawley@BSFLLP.com,brad@pathtojustice.com,[REDACTED] | Discussion of evidence among client and attorneys | AC Privilege and Work Product/joint defense/common interest | Withheld | 2 | msg | |
| 3 | 2/16/2015 15:37 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], McCawley, Pottinger and [REDACTED] re information provided by client to assist in legal advice | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 4 | 2/16/2015 16:15 | Sigrid McCawley | [REDACTED] | Email chain with [REDACTED], McCawley, Pottinger and [REDACTED] re information provided by client to assist in legal advice | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 5 | 2/16/2015 16:24 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], McCawley, Pottinger and [REDACTED] re information provided by client to assist in legal advice | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 6 | 2/16/2015 16:24 | Sigrid McCawley | [REDACTED] | Email chain with [REDACTED], McCawley, Pottinger and [REDACTED] re information provided by client to assist in legal advice | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 7 | 2/21/2015 16:45 | Sigrid McCawley | StanPottinger@aol.com,brad@pathtojustice.com,cassellp@law.utah.edu,[REDACTED] | Smccawley@BSFLLP.com | Discussion of evidence among client and attorneys | AC Privilege and Work Product/joint defense/common interest | Withheld | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work Product/joint defense/commo | Action | Page Count | Type |
| 8 2/21/2015 16:58 Smccawley@BSFLLP.com Discussion of evidence among client and attorney | |||
| n interest AC Privilege and Work StanPottinger@aol.com,cassellp@I Product/joint aw.utah.edu defense/commo | Withheld | 2 | Illsg |
| 9 2/21/2015 17:05 Brad Smccawley@BSFLLP.com | |||
| n interest AC Privilege and Work Product/joint defense/commo | Withheld | 2 | msg |
| 10 2/21/2015 17:10 Sigrid McCawley Discussion of evidence among client and attorney | |||
| n interest AC Privilege and Work Product/joint defense/commo | Withheld | 3 | msg |
| 11 2/21/2015 17:16 Hir-7::ampv./::::HIIHHHIIIIIIHiorrni Discussion of evidence among client and attorneys | |||
| n interest AC Privilege and Work StanPottinger@aol.com,brad@pat Product/joint htojustice.com,cassellp@law.utah. defense/commo | Withheld | 3 | msg |
| 12 2/23/2015 14:21 Sigrid McCawley | |||
| edu Discussion of thoughts and impressions of attorneys | |||
| n interest AC Privilege and Work Product/joint defense/commo | Withheld | i | msg |
| 13 2/23/2015 14:29 StanPottinger@aol.com | |||
| law.utah.edu Discussion of thoughts and impressions of attorneys | |||
| n interest AC Privilege and Work StanPottinger@aol.com,brad@pat Product/joint htojustice.com,cassellp@law.utah. defense/commo | Withheld | 1 | msg |
| 14 2/23/2015 16:01 Smccawley@BSFLI.P.com | |||
| edu Discussion of thoughts and impressions of attorneys | |||
| n interest | Withheld | 1 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work Product/joint | Action | Page Count | Type |
| 15 2/24/2015 17:51 Sigrid McCawley | |||
| Email chain with McCawley, =. and Paralegals re seeking defense/commo | |||
| n interest AC Privilege and Work Product/joint defense/commo | Withheld | 4 | msg |
| 16 Attached case research | |||
| n interest AC Privilege and Work Product/joint | Withheld | 14 | rtf |
| 17 2/26/2015 12:59 Smccawley@BSFLLP.com | |||
| Email chain with =, McCawley and legal assistant re legal defense/commo | |||
| n interest document, with attachment AC Privilege and Work Product/joint defense/commo | Withheld | 1 | msg |
| 18 Attached draft legal document | |||
| n interest AC Privilege and Work Product/joint | Withheld | 1 | jfif |
| 19 2/28/2015 17:47 Smccawley@ESSFLIP.com | |||
| Email with =,. McCawley, and re defense/commo | |||
| n interest discussion of draft statement AC Privilege and Work Product/joint | Withheld | 3 | msg |
| 20 3/13/2015 17:29 Stan Pottinger | |||
| Email chain with= McCawley, and defense/commo Smccawley@BSFILP.com,brad@pa | |||
| n interest thtojustice.com Pottinger re legal advice on media issues AC Privilege and Work Product/joint | Withheld | 2 | msg |
| 21 3/13/2015 17:49 stanpottinger@aol.com | |||
| Email chain with= McCawley and Pottinger re defense/commo | |||
| n interest legal advice on media issues | Withheld | 2 | msg |
| Log | Privilege Doc | |
|---|---|---|
| ID | Email Sent Date | Email From Email To CC Address Subject Matter Type of Privilege |
| Action Page Count Type AC Privilege and Work Product/joint | ||
| 22 | 3/13/2015 17:56 | StanPottinger@aol.com |
| Email chain with =, McCawley, Smccawley@BSFLLP.com,brad@pa and defense/commo | ||
| n interest Withheld 3 Ill sg thtojustice.com Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 23 | 3/13/2015 18:00 | Brad |
| Email chain with =, McCawley, and StanPottinger@aolcom. defense/commo | ||
| n interest Withheld 3 msg Smccawley@BSFLLP.com Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 24 | 3/13/2015 18:24 | brad@pathtojustice.com |
| Email chain with I, McCawley, and defense/commo | ||
| n interest Withheld 4 msg Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 25 | 3/13/2015 18:25 | StanPottinger@aol.com |
| Email chain with Mg S McCawley, and defense/commo | ||
| n interest Withheld 3 msg Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 26 | 3/13/2015 21:53 | brad@pathtojustice.com |
| Email chain with =, S McCawley, Smccawley@BSFLLP.com,StanPotti and defense/commo | ||
| n interest Withheld 4 msg nger@aol.com Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 27 | 3/13/2015 23:38 | Brad |
| Email chain with= McCawley, and defense/commo | ||
| n interest Withheld 4 msg Pottinger re legal advice on media issues AC Privilege and Work Product/joint | ||
| 28 | 3/13/2015 23:40 | brad@pathtojustice.com |
| Email chain with =II, McCawley, and defense/commo | ||
| n interest Withheld 4 msg Pottinger re legal advice on media issues |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint Smccawley@BSFILP.com,br defense/commo n interest/work ad@pathtojustice.com,stan | Action | Page Count | Type |
| 29 3/17/2015 15:20 | |||
| product pottinger@aol.com action, with attachments Attorney Client/joint Smccawley@BSFLLP.com,br defense/commo | Withheld | 1 | msg |
| 30 3/17/2015 18:40 Stan | |||
| ad@pathtojustice.comM Email chain with =, I, Pottinger and McCawley re n interest/work | |||
| product legal advice related to VRS Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 31 3/17/2015 19:42 stanpottinger@aol.com | |||
| Email chain with=S Pottinger and McCawley re n interest/work | |||
| product legal advice related to VRS Attorney Client/joint brad@pathtojustice.comi defense/commo | Withheld | 1 | msg |
| 32 3/20/2015 15:43 Sigrid McCawley | |||
| Email chain with Pottinger, tan aortiz@BSFILP.com,brittany@path n interest/work pottinger@aol.com | |||
| product tojustice.com Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 33 3/20/2015 15:57 Sigrid McCawley Providing legal advice re potential deposition | |||
| product Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 34 3/24/2015 21:19 Sigrid McCawley aortiz@BSFILP.com | |||
| Email chain with =S McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS | Withheld | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo | Action | Page Count | Type |
| 35 3/24/2015 21:21 Smccawley@BSFLLP.com aortiz@BSFLLP.com | |||
| Email chain with McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 36 3/24/2015 21:36 Andres Ortiz | |||
| Smccawley@BSILLP.comi Email chain with l=,I, McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 37 3/24/2015 22:21 aortiz@BSFLLP.com | |||
| Email chain with =S McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS Attorney Smccawley@BSFLLP.com,StanPotti Client/joint nger@aol.com,brad@pathtojustice defense/commo | Withheld | 3 | msg |
| 38 3/26/2015 2:00 Sigrid McCawley | |||
| .com,brittany@pathtojustice.com,e Email chain with Pottinger, n interest/work | |||
| product Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 39 3/26/2015 2:21 Smccawley@BSFLI.P.com | |||
| Email chain with =I MI, McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 40 3/26/2015 2:22 Sigrid McCawley | |||
| Email chain with =S McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS | Withheld | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo | Action | Page Count | Type |
| 41 3/26/2015 3:00 Smccawley@BSFLLP.com | |||
| Email chain with _, McCawley and n interest/work | |||
| product BSF staff re legal advice related to VRS Attorney Client/joint defense/commo n interest/work | Withheld | 2 | msg |
| 42 4/1/2015 21:32 Smccawley@BSEllAcom legal advice with attachments | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 43 4/2/2015 7:01 Brittany eperez@BSFLLP.com | |||
| product attachment AC Privilege and Work Product/joint defense/commo | Withheld | 1 | msg |
| 44 Attached Draft legal document | |||
| n interest AC Privilege and Work Product/joint | Withheld | 15 | |
| 45 4/3/2015 15:32 Brittany | |||
| Email chain with =, and legal brad@pathtojustice.com,eperez@ defense/commo | |||
| n interest 85FLLP.com AC Privilege and Work Product/joint defense/commo | Withheld | 2 | msg |
| 46 Attached draft legal document | |||
| n interest | 15 |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo n interest/work | Action | Page Count | Type |
| 47 4/8/2015 20:34 Smccawley@BSFILP.com Seeking legal advice related to VRS | |||
| product Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 48 4/9/2015 3:23 Smccawley@BSFILP.com | |||
| Email chain with and McCawley re advice re legal filings, n interest/work | |||
| product with attachments Attorney Client/joint defense/commo StanPottinger@aol.com,bra | Withheld | 2 | msg |
| 49 4/9/2015 7:16 Sigrid McCawley | |||
| d®pathtojustice.com brittany@pathtojustice.com,sperki | |||
| Email chain with =, McCawley and n interest/work | |||
| product ns@BSFLI.P.com BSF staff re legal advice re media issues Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 50 4/9/2015 9:26 Brad Smccawley@BSFLIP.com | |||
| Email chain with In MI. and McCawley re legal advice n interest/work re media issues | |||
| product Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 51 4/9/2015 9:33 Sigrid McCawley | |||
| Email chain with and McCawley re legal advice re media n interest/work | |||
| product issues AC Privilege and Work Product/joint defense/commo | Withheld | 2 | msg |
| 52 4/9/2015 12:46 Sigrid McCawley | |||
| n interest attachments | Withheld | 1 | I msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work Product/joint defense/commo | Action | Page Count | Type |
| n interest attachments AC Privilege and Work Product/joint defense/commo | Withheld | 14 | docx |
| n interest attachments AC Privilege and Work Product/joint defense/commo | Withheld | 12 | docx |
| n interest attachments Attorney Client/joint defense/commo StanPottinger@aol.com,brad@pat n interest/work | Withheld | 2 | docx |
| 56 4/10/2015 14:59 Sigrid McCawley | |||
| htojustice.com Providing legal advice re media issues | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 57 4/10/2015 15:37 Smccawley@BSFLLP.com Regarding legal advice re media issues | |||
| product AC Privilege and Work | withheld | 1 | msg |
| 58 4/10/2015 17:31 Sigrid McCawley | |||
| Email chain with =, McCawley, StanPottinger@aol.com,brad@pat Product/joint htojustice.com,brittany@pathtojus defense/commo | |||
| n interest tice.com,eperez@BSFLIP.com attachments AC Privilege and Work Product/joint defense/commo | Withheld | 2 | msg |
| 59 Attached draft legal document | |||
| n interest | Withheld | 3 | pdt |
| Log | Privilege | Doc | ||||||
|---|---|---|---|---|---|---|---|---|
| ID | Email Sent Date | Email From | Email To CC Address | Subject Matter | Type of Privilege | |||
| AC Privilege and Work Product/joint defense/commo | Action | Page Count | Type | |||||
| 60 | Attached draft legal document | |||||||
| n interest Attorney Client/joint defense/commo n interest/work | Withheld | 21 | ||||||
| 61 | 4/10/2015 17:40 | Smccawley@BSRLP.com | ||||||
| Email chain with = | McCawley and BSF staff regarding legal | |||||||
| advice related to VRS | product Attorney Client/joint defense/commo | Withheld | 2 | msg | ||||
| 62 | 4/10/2015 19:10 | Smccawley@BSFLLP.com | ||||||
| Email chain with l= | McCawley and BSF staff regarding legal n interest/work | |||||||
| advice related to VR5 | product Attorney Client/joint defense/commo | Withheld | 2 | msg | ||||
| 63 | 4/10/2015 19:28 | Sigrid McCawley | ||||||
| Email chain with = | McCawley and BSF staff regarding legal n interest/work | |||||||
| advice related to VRS | product Attorney Client/joint defense/commo | Withheld | 2 | msg | ||||
| 64 | 4/10/2015 19:33 | Smccawley@BSFLI.P.com | ||||||
| Email chain with IM, | McCawley and BSF staff regarding legal n interest/work | |||||||
| advice related to VRS | product Attorney Client/joint defense/commo | Withheld | 2 | msg | ||||
| 65 | 4/10/2015 20:03 | Sigrid McCawley | ||||||
| Email chain with l= | McCawley and BSF staff regarding legal n interest/work | |||||||
| advice related to VRS | product | Withheld | 2 | msg |
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 66 | 4/10/2015 20:04 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], McCawley and BSF staff regarding legal advice related to VRS | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 67 | 4/10/2015 20:04 | Sigrid McCawley | [REDACTED] | Email chain with [REDACTED], McCawley and BSF staff regarding legal advice related to VRS | Attorney Client/joint defense/common interest/work product | Withheld | 2 | msg | |
| 68 | 4/10/2015 23:46 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], McCawley legal assistant re seeking and providing information sought by attorney to assist in providing legal advice, with attachments | AC Privilege and Work Product/joint defense/common interest | Withheld | 3 | msg | |
| 69 | 4/13/2015 13:52 | Sigrid McCawley | [REDACTED] | StanPottinger@aol.com,brad@pathtojustice.com | Email chain with [REDACTED], Pottinger, [REDACTED] and McCawley re legal advice regarding potential public statements | AC Privilege and Work Product/joint defense/common interest | Withheld | 3 | msg |
| 70 | 4/13/2015 13:56 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], Pottinger, [REDACTED] and McCawley re legal advice regarding media issues | AC Privilege and Work Product/joint defense/common interest | Withheld | 3 | msg | |
| 71 | 4/14/2015 23:38 | Brad [REDACTED] | Smccawley@BSFLLP.com,brittany@pathtojustice.com [REDACTED] stanpottinger@aol.com | Providing legal advice related to VRS | Attorney Client/joint defense/common interest/work product | Withheld | 1 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo | Action | Page Count | Type |
| 72 4/16/2015 11:14 Smccawley@BSFILP.com | |||
| Email chain with and McCawley re legal advice regarding n interest/work | |||
| product media issues Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 73 4/16/2015 11:47 Sigrid McCawley | |||
| Email chain with and McCawley re legal advice regarding n interest/work media issues | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 2 | msg |
| 74 4/24/2015 19:22 Sigrid McCawley Providing legal advice re records retention, with attachments | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| product Attorney Client/joint defense/commo | Withheld | 2 | |
| 76 4/24/2015 19:59 Smccawley@BSRLP.com | |||
| Email chain with and McCawley re legal advice regarding n interest/work | |||
| product potential deposition Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 77 4/27/2015 21:20 Brad Smccawley@BSFELP.com Seeking information to assist in providing legal advice | |||
| product | Withheld | 1 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work Product/joint Smccawley@B5FLLP.com,brad@Pa thtojustice.com defense/commo | Action | Page Count | Type |
| 78 4/30/2015 6:42 Brittany eperez@BSFLLP.com | |||
| n interest Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 79 4/30/2015 7:02 Brittany | |||
| Email chain with =, and paralegal re seeking n interest/work | |||
| product AC Privilege and Work | Withheld | 2 | msg |
| 80 4/30/2015 7:05 brittany@pathtojustice.com | |||
| Email chain with =, McCawley and Product/joint defense/commo | |||
| n interest advice AC Privilege and Work | Withheld | 2 | msg |
| 81 5/4/2015 20:04 brittany@pathtojustice.com | |||
| Email chain with= I, McCawley and Product/joint defense/commo | |||
| n interest advice, with attachment AC Privilege and Work | Withheld | 2 | msg |
| 82 5/11/2015 18:20 Sigrid McCawley Smccawley@BSFLLP.com | |||
| Email chain with McCawley, =, Pottinger, Product/joint defense/commo | |||
| n interest AC Privilege and Work | Withheld | 1 | msg |
| 83 5/11/2015 18:34 Smccawley@BSFLLP.com | |||
| Email chain with` McCawley, Pottinger and Product/joint defense/commo | |||
| n interest advice re potential litigation AC Privilege and Work Product/joint | Withheld | 2 | msg |
| 84 5/11/2015 18:40 Sigrid McCawley | |||
| Email chain with and McCawley re case research, with defense/commo | |||
| n interest attachment | MOM Id | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work Product/joint | Action | Page Count | Type |
| 85 5/11/2015 18:45 Sigrid McCawley | |||
| brad@pathtojustice.comj Providing and seeking information to assist in legal advice re defense/commo | |||
| n interest potential legal action, with attachment Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 86 I 5/11/2015 18:47 Smccawley@BSRLP.com | |||
| Email chain with and McCawley re seeking information n interest/work | |||
| product AC Privilege and Work | Withheld | 1 | msp, |
| 87 5/11/2015 18:56 brad@pathtojustice.com | |||
| Email chain with = McCawley, Pottinger and Product/joint defense/commo | |||
| n interest advice re potential litigation Attorney Client/joint defense/commo n interest/work | Withheld | 2 | msg |
| 88 I 5/17/2015 22:37 Sigrid McCawley Providing litigation documents to client, with attachments | |||
| product AC Privilege and Work Product/joint defense/commo | Withheld | 3 | msp, |
| 89 , Attached draft legal agreement | |||
| n interest Attorney Client/joint defense/commo n interest/work | Withheld | 10 | |
| 90 I 5/17/2015 22:40 Sigrid McCawley Providing legal advice re legal agreement, with attachment | |||
| product AC Privilege and Work Product/joint defense/commo | Withheld | 1 | msg |
| 91 I 5/18/2015 18:40 Smccawley@BSRLP.com Discussion of confidential agreement, with attachments | |||
| n interest | Withheld | 1 | msp, |
Plaintiff Revised Supplemental Privilege Log dated June 9, 2016¶
| Log | Privilege | Doc | |
|---|---|---|---|
| a) F. mail sent ()JR. Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo n interest/work | Action | Page Count | Type |
| 92 Attached confidential agreement page | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | jfif |
| 93 Attached confidential agreement page | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | jfif |
| 94 6/5/2015 19:16 Sigrid McCawley Conveying attorney mental impression regarding hearing | |||
| product Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 95 6/6/2015 17:20 Smccawley@BSFUP.com | |||
| Email chain with and McCawley re attorney mental n interest/work impression regarding hearing | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 96 6/25/2015 2:26 Sigrid McCawley Providing advice re status and strategy of ongoing legal matters | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 6 | msg |
| 97 7/17/2015 14:19 Sigrid McCawley eperez@BSFLLP.com | |||
| product representation by 8. losefsberg | Withheld | 4 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date• Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo n interest/work | Action | Page Count | Type |
| 98 7/27/2015 21:53 Smccawley@BSFILP.com | |||
| product litigation Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 99 7/29/2015 19:45 Sigrid McCawley StanPottinger@aol.com Conveying legal advice on media issues | |||
| product AC Privilege and Work Product/joint | Withheld | 1 | msg |
| 100 8/5/2015 19:51 Sigrid McCawley | |||
| Email chain with l= McCawley and paralegals re defense/commo | |||
| n interest AC Privilege and Work | Withheld | 1 | msg |
| 101 8/6/2015 2:14 Sigrid McCawley | |||
| Email chain with l= McCawley, legal intern and paralegal Product/joint defense/commo | |||
| n interest potential litigation AC Privilege and Work | Withheld | 2 | msg |
| 102 8/6/2015 2:45 Sigrid McCawley brad@pathtojustice.com | |||
| Email chain with l=, McCawley, legal intern, and Product/joint defense/commo | |||
| n interest advice re potential litigation AC Privilege and Work | Withheld | 2 | msg |
| 103 8/6/2015 2:55 Smccawley@BSELLP.com | |||
| Email chain with = McCawley, legal intern and paralegal Product/joint defense/commo | |||
| n interest potential litigation AC Privilege and Work Product/joint | Withheld | 2 | msg |
| 104 8/6/2015 3:48 Sigrid McCawley | |||
| Email chain with McCawley, and Paralegals re seeking Smccawley@BSFLLP.com,brad@pa defense/commo | |||
| n interest thtojustice.com | Withheld | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| AC Privilege and Work | Action | Page Count | Type |
| 105 8/6/2015 3:51 Smccawley@BSELLP.com | |||
| Email chain with l= McCawley, legal intern and paralegal Product/joint defense/commo potential litigation | |||
| n interest AC Privilege and Work Product/joint brad@pathtojustice.com,brittany@ defense/commo | Withheld | 2 | msg |
| 106 9/1/2015 18:54 Sigrid McCawley | |||
| n interest pathtojustice.com potential legal action, with attachment Attorney Client/joint brad@pathtojustice.com,sm defense/commo ccawley@bsfIlp.com,stanpot n interest/work | Withheld | 2 | msg |
| 107 9/7/2015 18:24 | |||
| product tinger@aol.com advice, with attachment AC Privilege and Work Product/joint defense/commo | Withheld | 1 | msg |
| n interest advice Attorney Client/joint | Withheld | 4 | dock |
| 109 9/7/2015 18:58 Sigrid McCawley | |||
| brad@pathtojustice.coma Email chain with l=,I . Pottinger and McCawley re defense/commo n interest/work stan | |||
| product potential litigation pottinger@aol.com Attorney Client/joint defense/commo | Withheld | 1 | msg |
| 110 9/15/2015 21:58 Smccawley@l3SHIP.com | |||
| Email chain with and McCawley re draft legal document n interest/work | |||
| product relating to litigation | Withheld | 1 | msg |
| log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo | Action | Page Count | Type |
| in 9/15/2015 22:04 Sigrid McCawley | |||
| Email chain with and McCawley re draft legal document n interest/work | |||
| product relating to litigation Attorney Client/joint defense/commo | Withheld | 2 | msg |
| 112 9/15/2015 22:07 Smccawley@BSRLP.com | |||
| Email chain with and McCawley re draft legal document n interest/work relating to litigation | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 2 | msg |
| 113 i 9/20/2015 12:15 Sigrid McCawley brad@pathtojustice.com Conveying information about potential legal action. | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 114 9/20/2015 14:47 Smccawley@BSFLIP.com Email chain with and McCawley re potential legal action. | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 115 9/20/2015 19:16 Smccawley@BSRLP.com Email chain with and McCawley re potential legal action. | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 1 | msg |
| 116 9/20/2015 19:29 Sigrid McCawley Email chain with and McCawley re potential legal action. | |||
| product | Withheld | 2 | msg |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege | |||
| Attorney Client/joint defense/commo n interest/work | Action | Page Count | Type |
| 117 9/20/2015 19:30 Smccawley@ESSFILP.com Email chain with and McCawley re potential legal action. | |||
| product AC Privilege and Work Product/joint defense/commo | Withheld | 2 | msg |
| 118 9/21/2015 14:48 Sigrid McCawley Communication re initiation of lawsuit, with attachments | |||
| n interest AC Privilege and Work Product/joint defense/commo | Withheld | 1 | msg |
| 119 Attached draft legal document relating to litigation | |||
| n interest Attorney Client/joint defense/commo n interest/work | Withheld | 12 | |
| 120 Attached draft legal document relating to litigation | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 2 | |
| 121 Attached draft legal document relating to litigation | |||
| product Attorney Client/joint defense/commo n interest/work | Withheld | 2 | |
| 122 Attached draft legal document relating to litigation | |||
| product | Withheld | 3 |
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 123 | 9/21/2015 14:51 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED] and McCawley re potential legal action. | Attorney Client/joint defense/common interest/work product | Withheld | 1 | msg | |
| Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2 v. United States ("CVRA case"), Case no. 08-80736-CIV-Marra, pending in the Southern District of Florida. Documents withheld pursuant to the privileges asserted included communications from [REDACTED] to the attorneys listed seeking legal advice related to the CVRA case, communications from the attorneys to [REDACTED] giving legal advice or giving attorney mental impressions related to the CVRA case, communications sending or attaching attorney work product related to the CVRA case, and/or communications sending or attaching client revisions to attorney work product related to the CVRA case, and communications re evidence. | AC Privilege and Work Product/joint defense/common interest | Withheld | Approx. 1.3K docs overlapping with other cases | ||||||
| 125 | Emails, letters, and other communications from 2011 - Present | [REDACTED] | Brad [REDACTED], Paul Cassell, Brittany [REDACTED] (and other, Sigrid McCawley, Meredith [REDACTED], David Boies, Jack Scarola, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and representation | [REDACTED], Brad [REDACTED], Paul Cassell, Brittany [REDACTED], Sigrid McCawley, Meredith [REDACTED], David Boies, Jack Scarola, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and representation |
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 126 | Emails, letters, and other communications from 9/21/15 - Present | Brad Brittany, Paul Cassell, Sigrid McCawley, Meredith Boies, Stephen Zach, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and representation | Brad Brittany, Paul Cassell, Sigrid McCawley, Meredith Boies, Stephen Zach, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and | Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: [REDACTED] v. Maxwell ("Maxwell case"), 15-cv-07433-RWS, pending in the Southern District of New York, since the date of filing, September 21, 2015. Documents withheld pursuant to the privileges asserted included communications from [REDACTED] to the attorneys listed seeking legal advice related to the Maxwell case, communications from the attorneys to [REDACTED] giving legal advice or giving attorney mental impressions related to the Maxwell case, communications sending or attaching attorney work product related to the Maxwell case, and/or communications sending or attaching client revisions to attorney work product related to the Maxwell case, and communications re evidence. | AC Privilege and Work Product/joint defense/common interest | Approx. 1.3K docs overlapping with other cases |
| Log | Privilege Doc |
|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter | Type of Privilege |
| Action Page Count Type Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, | |
| Meredith M, David | |
| Brittany S Sigrid | |
| Rule 26.2(c). Correspondence re: Brad Paul Cassell, Cassell v Brittany S Brad Sigrid McCawley, Paul Cassell, | and Paul pending in the Seventeenth Judicial Circuit, Broward County, Florida. Documents withheld pursuant to the privileges |
| asserted included communications from Boies, Stephen Zach, McCawley, Meredith | to the attorneys listed seeking legal advice related to the |
| case, communications from the attorneys to Stan Pottinger, Ellen David Boies, Brockman, Legal Stephen Zach, Stan Assistants, Professionals Pottinger, Ellen Brockman, | giving case, communications sending or attaching attorney AC Privilege and Approx. 1.3K |
| work product related to the Emails, letters, and retained by attorneys to Legal Assistants, other communications aid in the rendition of Professionals retained by attorneys to aid in the | case, and/or Work dots overlapping communications sending or attaching client revisions to Product/joint with other |
| attorney work product related to the from January 2015 - legal advice and | case, and defense/commo |
| rendition of legal advice and Present representation communications re evidence. | n interest Withheld cases |
| Log | Privilege | Doc | |
|---|---|---|---|
| ID Email Sent Date Email From Email To CC Address Subject Matter T •e of Privile:e | |||
| Bob Bob Josefsberg, Katherine W. losefsberg, Katherine W. Ezell, Amy Ederi, other Ezell, Amy Ederi, other Podhurst attorneys, Podhurst attorneys, Legal AC Privilege and Legal Assistants, and Assistants, and Professionals Work Emails, letters, and Professionals retained by retained by attorneys to aid Product/joint in the rendition of legal other communications attorneys to aid in the defense/commo | Action | Pare Count | Type |
| n interest from 2009 - Present rendition of legal advice advice communications re evidence. | Withheld | ||
| 129 6/10/2015 | |||
| Email chain with and McCawley seeking information to | |||
| assist with attorney advice. Attorney Client | Withheld | 2 | msg |
| Letter from to David Boies conveying requested AC Privilege and | |||
| Work Product Smccawley@BSFLLP.com,brad@pa AC Privilege and thtojustice.com | Withheld | 26 | |
| 131 4/30/2015 Brittany eperez@BSFLLP.com | |||
| Work Product Communication re VRS registrations Smccawley@BSFLLP.com,brad@pa | Withheld | 1 | msg |
| 132 4/29/2015 Andres Ortiz bh699@nova.edu | |||
| thtojustice.com,garvin@lclark.edu, Email chain with McCawley, Garvin, AC Privilege and | |||
| Work Product Smccawley@BSFLLP.com,brad@pa thtojustice.com,garvin@lclark.edu, AC Privilege and | Withheld | 1 | msg |
| 133 4/29/2015 brittany aortiz@BSFILP.com | |||
| Work Product | Withheld | 1 | msg |
Plaintiff Revised Supplemental Privilege Log dated June 9, 2016¶
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 134 | 4/17/2015 | Paul Cassell | brad@pathtojustice.com | Smccawley@BSFLLP.com,brittany @pathtojustice.com,eperez@BSFLLP.com | Email chain with Cassell, McCawley, [REDACTED], Garvin, Beloof, [REDACTED], [REDACTED] and BSF staff re legal advice re VRS registrations. | AC Privilege and Work Product | Withheld | 5 | msg |
| 135 | 4/17/2015 | Sigrid McCawley | brad@pathtojustice.com,cassellp@law.utah.edu | brittany@pathtojustice.com,eperez@BSFLLP.com,[REDACTED] | Email chain with Cassell, McCawley, [REDACTED], Garvin, Beloof, [REDACTED], [REDACTED] and BSF staff re legal advice re VRS registrations. | AC Privilege and Work Product | Withheld | 4 | msg |
| 136 | 4/17/2015 | Brad [REDACTED] | cassellp@law.utah.edu | Smccawley@BSFLLP.com,brittany @pathtojustice.com,eperez@BSFLLP.com | Email chain with Cassell, McCawley, [REDACTED], Garvin, Beloof, [REDACTED], [REDACTED] and BSF staff re legal advice re VRS registrations. | AC Privilege and Work Product | Withheld | 4 | msg |
| 137 | 2/26/2015 | Sigrid McCawley | [REDACTED] | Email chain with [REDACTED] and McCawley re non-testifying expert. | Attorney Client | Withheld | 1 | msg | |
| 138 | 2/26/2015 | Sigrid McCawley | [REDACTED] | Communication re non-testifying expert. | Attorney Client | Withheld | 1 | msg | |
| 139 | 2/11/2016 | Sigrid McCawley | [REDACTED] | Email chain with [REDACTED], McCawley, [REDACTED], Pottinger and BSF staff re media communications. | Attorney Client | Redacted | 3 | msg | |
| 140 | 2/11/2016 | Sigrid McCawley | StanPottinger@aol.com,[REDACTED] | Lcarlsen@BSFLLP.com,brad@pathtojustice.com | Email chain with [REDACTED], McCawley, [REDACTED], Pottinger and BSF staff re media communications. | Attorney Client | Redacted | 3 | msg |
| 141 | 2/11/2016 | StanPottinger@aol.com | [REDACTED] | Lcarlsen@BSFLLP.com,Smccawley @BSFLLP.com,brad@pathtojustice.com | Email chain with [REDACTED], McCawley, [REDACTED], Pottinger and BSF staff re media communications. | Attorney Client | Redacted | 3 | msg |
| 142 | 2/9/2016 | StanPottinger@aol.com | [REDACTED] | Email chain with [REDACTED] and Pottinger re media communications. | Attorney Client | Redacted | 2 | msg | |
| 143 | Letter from [REDACTED] to David Boies conveying requested information to assist in providing legal advice. | AC Privilege and Work Product | Withheld | 26 | |||||
| 144 | Letter from [REDACTED] to David Boies conveying requested information to assist in providing legal advice. | AC Privilege and Work Product | Withheld | 23 | docx | ||||
| 145 | 6/10/2015 | [REDACTED] | [REDACTED] | Email chain with [REDACTED] and McCawley re ongoing litigation. | Attorney Client | Withheld | 2 | msg | |
| 146 | 4/29/2015 | [REDACTED] | aortiz@BSFLLP.com | Smccawley@BSFLLP.com,bh699@nova.edu,brad@pathtojustice.com,garvin@lclark.edu | Email chain with [REDACTED], McCawley, [REDACTED], Garvin and BSF staff re VRS communications. | Attorney Client | Withheld | 2 | msg |
| 147 | 4/10/2015 | [REDACTED] | [REDACTED] | Email chain with [REDACTED], McCawley, and BSF staff re legal advice re VRS registrations. | Attorney Client | Withheld | 2 | msg | |
| 148 | 2/26/2015 | [REDACTED] | Smccawley@BSFLLP.com | Email confirming legal advice re non-testifying expert. | Attorney Client | Withheld | 1 | msg |
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 149 | 2/11/2015 | [REDACTED] | StanPottinger@aol.com | Email chain with [REDACTED] and Pottinger re media communications | Attorney Client | Redacted | 3 | msg | |
| 150 | 2/11/2015 | [REDACTED] | Smccawley@BSFLLP.com | Email chain with [REDACTED], McCawley, Pottinger and BSF staff re media communications. | Attorney Client | Redacted | 3 | msg | |
| 151 | 1/13/2015 | [REDACTED] | StanPottinger@aol.com | Email chain with Pottinger and [REDACTED] re anticipated litigation. | AC Privilege and Work Product | Withheld | 1 | msg | |
| 152 | Emails, letters, and other communications from January 2015 - Present | [REDACTED], Brad [REDACTED], Paul Cassell, Brittany [REDACTED], Sigrid McCawley, Meredith [REDACTED], David Boies, Stephen Zach, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice | [REDACTED], Brad [REDACTED], Paul Cassell, Brittany [REDACTED], Sigrid McCawley, Meredith [REDACTED], David Boies, Stephen Zach, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice | Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). This categorical entry is regarding correspondence re potential legal action against entities and individuals. Documents withheld pursuant to the privileges asserted included communications from [REDACTED] to the attorneys listed seeking legal advice related to potential law suits, communications from the attorneys to [REDACTED] giving legal advice or giving attorney mental impressions related to the law suits, communications sending or attaching attorney work product related to potential lawsuits, and/or communications sending or attaching client revisions to attorney work product related to potential lawsuits, and communications re evidence. | [REDACTED] | AC Privilege and Work Product/joint defense/common interest | Withheld | Approx. 1.3K overlapping with other cases | |
| Log ID | Email Sent Date | Email From | Email To | CC Address | Subject Matter | Type of Privilege | Privilege Action | Page Count | Doc Type |
|---|---|---|---|---|---|---|---|---|---|
| 153 | Email and letter communications | The law enforcement entity, [REDACTED], David Boies, Stan Pottinger, Sigrid McCawley, Paul Cassell, Brad [REDACTED] | The law enforcement entity, [REDACTED], David Boies, Stan Pottinger, Sigrid McCawley, Paul Cassell, Brad [REDACTED] | Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). This categorical entry is regarding correspondence re the currently ongoing criminal investigation of Defendant and others. | Public Interest | Withheld | approx. 57 documents | ||
| 154 | 8/27/2014 | [REDACTED] | Brad [REDACTED] | Email chain discussing efforts to obtain assistance from FBI agent in obtaining information to assist in providing legal advice. | AC Privilege and Work Product | Withheld | 1 | msg | |
| 155 | 8/27/2014 | [REDACTED] | Brad [REDACTED] | Email chain discussing efforts to obtain assistance from FBI agent in obtaining information to assist in providing legal advice. | AC Privilege and Work Product | Withheld | 1 | msg | |
| 156 | 8/27/2014 | [REDACTED] | Brad [REDACTED] | Email chain discussing efforts to obtain assistance from FBI agent in obtaining information to assist in providing legal advice. | AC Privilege and Work Product | Withheld | 1 | msg |