EFTA00028927.pdf

Type: pdf
Source set: data-set-8
Extracted text

EXHIBIT P 
EFTA00028927


Log 
ID 
Email Sent Date 
Email From 
Email To 
CC Address 
It 
Subject Matter 
Type of Privilege 
Privilee 
Action 
Page Count 
Doc 
Type 
153 
Email and letter 
communications re law 
enforcement 
investigation 
The law enforcement 
entity. 
David Boles, Stan 
Pottinger, Sigrid 
McCawley, Paul Cassell, 
Brad Edwards 
The law enforcement entity, 
S 
David Boles, 
Stan Pottmger, Sigrid 
McCawley, Paul Cassell, Brad 
Edwards 
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 
EFTA00028928
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