EXHIBIT P
EFTA00028927
Log
ID Email Sent Date Email From Email To CC Address It Subject Matter
Privilee
Type of Privilege Action Page Count
Doc
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 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
The law enforcement outweighs its benefit. Therefore, Plaintiff has employed
entity. The law enforcement entity, categorical logging pursuant to Local Civil Rule 26.2(c).
Email and letter David Boles, Stan S David Boles, This categorical entry is regarding correspondence re the
communications re law Pottinger, Sigrid Stan Pottmger, Sigrid
currently ongoing criminal investigation of Defendant and
enforcement McCawley, Paul Cassell, McCawley, Paul Cassell, Brad approx. 57
others.
153 investigation Brad Edwards Edwards Public Interest Withheld documents
EFTA00028928