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Giuffre_Maxwell_Batch1_p00419.png

Source: GIUFFRE_MAXWELL  •  Size: 138.3 KB  •  OCR Confidence: 87.1%
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Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 27 of 27 log Privilege Doe 1p | Emailsent Date _|Email From Email To cc Address Subject Matter LType 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 The law enforcement that outweighs its benefit. Therefore, Plaintiff has lentity, Virginia Giuffre, |The law enforcement entity, lemployed categorical logging pursuant to Local Civil Rule David Boles, Stan Virginia Giuffre, David Boies, 26.2(c). This categorical entry is regarding correspondence Pottinger, Sigrid Stan Pottinger, Sigrid re the currently ongoing criminal investigation of Emailandletter — |McCawley, Paul Cassell, |McCawley, Paul Cassell, Brad| approx. 57 Defendant and others. 153 | communications _ [Brad Edwards Edwards Publicinterest_|Withheld | documents Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016

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Filename Giuffre_Maxwell_Batch1_p00419.png
File Size 138.3 KB
OCR Confidence 87.1%
Has Readable Text Yes
Text Length 1,368 characters
Indexed 2026-02-04 12:33:47.815865