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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 5 of 13 WL 1238785, at *2 (W.D.N.Y., 2016) (granting Plaintiff's motion to compel production of paragraph 5 of defendant’s joint defense agreement, since that paragraph is relevant to the claims and defenses). Cc. This Court should Order Production of Documents Responsive to Requests No 12. In this request, Ms. Giuffre seeks the documents that concern her. Defendant tells the Court, “[c]conspicuously missing is any explanation of why a request for ‘all documents concerning’ Plaintiff would not require review and production of every document the defense has in this case.” (Br. at 14). Both common sense and common attorney competencies belies this statement.” First, it is expected that the overwhelming majority of documents “concerning” Ms. Giuffre are attorney-client communications or work product created after the filing of this lawsuit. Such documents do not even require extensive review as they are protected by privilege, and can be categorically logged pursuant to the Local Rules and governing case law.’ Therefore, there is no merit to Defendant’s burden claim. Moreover, throughout the months of motion practice concerning these issues, and throughout all of the meet and confers, Defendant’s counsel has never presented a case supporting the far-fetched position that non-privileged documents in the possession of the > Furthermore, Ms. Giuffre’s correspondence suggesting just how these documents can be collected electronically without undue burden also belies any claim of ignorance on how to collect and produce documents responsive to this request without reviewing “thousands” of presumptively privileged communications. * See also Southern District of New York Local Civil Rule 26.2(c); Am. Broad. Companies, Inc. v. Aereo, Inc., 2013 WL 139560, at *2 (S.D.N.Y. Jan. 11, 2013) (“the Court notes that [parties] . . . are presented with a number of option that . . . could mitigate the burden . . . including... exclusion from the privilege logs of documents created after the commencement of litigation . . ..’) (Emphasis added); United States v. Bouchard Transp., 2010 WL 1529248, at *2 (E.D.N.Y. Apr. 14, 2010) (First, privilege logs are commonly limited to documents created before the date litigation was initiated. This is due to the fact that, in many situations, it can be assumed that all documents created after charges have been brought or a lawsuit has been filed and withheld on the grounds of privilege were created “because of” that pending litigation.” (Emphasis added).