Giuffre_Maxwell_Batch1_p00415.png

Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 23 of 27 log Privilege Doc 1D 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 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 Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Bradley Edwards and Paul Edwards, Paul Cassell, [Cassell v. Alan Dershowitz (“Dershowitz case”), Case no. 15- Brittany Henderson, Virginia Giuffre, Brad 000072, pending in the Seventeenth Judicial Circuit, Broward Sigrid McCawley, Edwards, Paul Cassell, County, Florida. Documents withheld pursuant to the privileges Meredith Schultz, David Brittany Henderson, Sigrid asserted included communications from Ms. Giuffre to the Boies, Stephen Zach, _ | McCawley, Meredith attorneys listed seeking legal advice related to the Dershowitz Stan Pottinger, Ellen Schultz, David Boies, case, communications from the attorneys to Ms. Giuffre giving Brockman, Legal Stephen Zach, Stan legal advice or giving attorney mental impressions related to the Assistants, Professionals |Pottinger, Ellen Brockman, Dershowitz case, communications sending or attaching attorney |AC Privilege and Approx. 1.3K Emails, letters, and _|retained by attorneys to |Legal Assistants, ]work product related to the Dershowitz case, and/or Work docs other communications aid in the rendition of _ | Professionals retained by lcommunications sending or attaching client revisions to Product/joint overlapping from January 2015 - |legal advice and attorneys to aid in the attorney work product related to the Dershowitz case, and _|defense/commo with other 227 Present representation rendition of legal advice and communications re evidence. n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016