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Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 35 of 35 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 The law enforcement that outweighs its benefit. Therefore, Plaintiff has lentity, Virginia Giuffre, |The law enforcement entity, employed categorical logging pursuant to Local Civil Rule David Boies, 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 Email and letter McCawley, Paul Cassell, |IMcCawley, Paul Cassell, Brad} Defendant and others. approx. 57 153 | _communications _|Brad Edwards Edwards Public interest _|withheld | documents Email chain discussing efforts to obtain assistance from FB _ AC Privilege and 154 8/27/2014 Virginia Giuffre Brad Edwards [agent in obtaining information to assist in providing legal advice. |Work Product _|Withheld 1 msg Email chain discussing efforts to obtain assistance from FBI —_ AC Privilege and 155 8/27/2014 Virginia Giuffre Brad Edwards [agent in obtaining information to assist in providing legal advice. |Work Product _|Withheld 1 msg Email chain discussing efforts to obtain assistance from FB _ AC Privilege and 156 8/27/2014 Virginia Giuffre Brad Edwards [agent in obtaining information to assist in providing legal advice. |Work Product _|Withheld 1 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016