EFTA00028927.pdf

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