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Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 26 of 27 log Privilege Doc 1D EmailSent Date _|Email From [Email To icc Address Subject Matter {Type of Privilege [Action Page Count | Type Email chain with Giuffre and Pottinger re media 149 2/11/2015 Virginia Giuffre StanPottinger@aol.com communications Attorney Client |Redacted 3 msg Email chain with Giuffre, McCawley, Pottinger and BSF staff re 150 2/11/2015 Virginia Giuffre ISmccawley@BSFLLP.com media communications. Attorney Client |Redacted 3 msg |AC Privilege and 151 1/13/2015 Virginia Giuffre StanPottinger@aol.com Email chain with Pottinger and Giuffre re anticipated litigation. |Work Product |Withheld 1 msg 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 potential legal action against entities and individuals. Virginia Giuffre, Brad Documents withheld pursuant to the privileges asserted Edwards, Paul Cassell, | Virginia Giuffre, Brad included communications from Ms. Giuffre to the Brittany Henderson, Edwards, Paul Cassell, attorneys listed seeking legal advice related to potential Sigrid McCawley, Brittany Henderson, Sigrid law suits, communications from the attorneys to Ms. Meredith Schultz, David |McCawley, Meredith fur, Boies stephen Zach, |schulte,Devid Boies Giuffre giving legal advice or giving attorney mental stan Pottinger, Ellen Stephen Zach, Stan impressions related to the law suits, communications Brockman, Legal Pottinger, Ellen Brockman, sending or attaching attorney work product related to |AC Privilege and Emails, letters, and Assistants, Professionals |Legal Assistants, Potential lawsuits, and/or communications sending or —_ work Approx. 1.3K other communications |retained by attorneys to [Professionals retained by attaching client revisions to attorney work product related |product/joint overlapping from January 2015- aid inthe rendition of __|attorneys to aid in the to potential lawsuits, and communications re evidence. _|defense/commo with other 152 Present legal advice rendition of legal advice n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016