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Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 29 of 35 Log Privilege Doc 1D Email Sent Date__|Email From Email To CC Address Subject Matter [Type of Privilege |Action Page Count | Type Attorney Client/joint defense/commo n interest/work 123 | 9/21/2015 14:51 _|Virginia Giuffre smecawley @BSFLLI [Email chain with Giuffre and McCawley re potential legal action. |product Withheld msg 125 Emails, letters, and other communications from 2011 - Present Virginia Giuffre, Brad Edwards, Paul Cassell, Brittany Henderson (and other , Sigrid McCawley, Meredith Schultz, David Boies, Jack Scarola, Stan Pottinger, Ellen Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and representation Virginia Giuffre, Brad Edwards, Paul Cassell, Brittany Henderson, Sigrid McCawley, Meredith ‘Schultz, David Boies, Jack Scarola, Stan Pottinger, Ellen’ Brockman, Legal Assistants, Professionals retained by attorneys to aid in the rendition of legal advice and representation 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). Correspondence re: Jane Doe #1 and Jane Doe #2 \v. United States ("CVRA case"), Case no. 08-80736-CIV-Marra, pending in the Southern District of Florida. Documents withheld pursuant to the privileges asserted included communications from Ms. Giuffre to the attorneys listed seeking legal advice related to the CVRA case, communications from the attorneys {to Ms. Giuffre giving legal advice or giving attorney mental impressions related to the CVRA case, communications sending lor attaching attorney work product related to the CVRA case, and/or communications sending or attaching client revisions to attorney work product related to the CVRA case, and communications re evidence. |AC Privilege and Work Product/joint Jdefense/commo ninterest Withheld a CS CC Approx. 1.3K docs overlapping with other cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016