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Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 22 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: Giuffre v. Maxwell (“Maxwell Edwards, Paul Cassell, case”), 15-cv-07433-RWS, pending in the Southern District of Brittany Henderson, —_| Virginia Giuffre, Brad New York, since the date of filing, September 21, 2015. Sigrid McCawley, Edwards, Paul Cassell, Documents withheld pursuant to the privileges asserted Meredith Schultz, David [Brittany Henderson, Sigrid included communications from Ms. Giuffre to the attorneys Boies, Stephen Zach, | McCawley, Meredith listed seeking legal advice related to the Maxwell case, Stan Pottinger, Ellen _|Schultz, David Boies, communications from the attorneys to Ms. Giuffre giving legal Brockman, Legal Stephen Zach, Stan advice or giving attorney mental impressions related to the Assistants, Professionals |Pottinger, Ellen Brockman, Maxwell case, communications sending or attaching attorney _| AC Privilege and Approx. 1.3K retained by attorneys to |Legal Assistants, work product related to the Maxwell case, and/or Work docs Emails, letters, and aid in the rendition of _| Professionals retained by communications sending or attaching client revisions to Product/joint overlapping other communications |legal advice and attorneys to aid in the attorney work product related to the Maxwell case, and ldefense/commo with other 126 | from 9/21/15 - 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