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Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 4 of 15 Regarding “burdensomeness,” Ms. Ransome is represented by at least five attorneys from three different firms.' She first spoke to those attorneys sometime in October or November 2016, so the entire volume of their communications cannot be significant, and she submits no proof to the Court that it is. She has offered no explanation as to why her five (or six) attorneys are unable to prepare a privilege log as to their communications with her, or any other documents withheld as privileged. The cases cited by Plaintiff do not support her position. For example, Wells Fargo Bank, N.A. has nothing to do with privilege logs and, in fact, holds to the contrary: “The permissible scope of discovery from a non-party is generally the same as that applicable to discovery sought from parties.” Wells Fargo Bank, N.A. v. Konover, No. 3:05CV 1924 CFD/WIG, 2009 WL 585434, at *4 (D. Conn. Mar. 4, 2009). The non-party witness in Med. Components, Inc. v. Classic Med., Inc., 210 F.R.D. 175, 180 (M.D.N.C. 2002), actually offered to provide a privilege log. And the non-party witness in Tucker v. Am. Int’l Grp, Inc., 281 F.R.D. 85 (D. Conn. 2012), fully complied with two previous discovery requests but objected to inspection of its electronic servers to locate emails whose existence was speculative. Ms. Ransome’s second argument, the unremarkable position that witness interviews are covered by work product protection, does nothing to address the issue in question, i.e., whether she should have provided a privilege log identifying any such privileged documents. Rule 45(e)(2)(A) requires as to any withheld document “subject to protection as trial-preparation material,” a non-party witness must “(i) expressly make the claim; and (ii) describe the nature of ‘It is “at least” five attorneys because, when asked, Ms. Ransome testified that she is represented by Mr. Guirguis (who appeared at her deposition but has not entered an appearance in this case), Mr. Boies, Ms. McCawley, Mr. Pottinger and Mr. Edwards, but she denied being represented by Mr. Cassell, despite the fact that she has a signed fee agreement with him. Pottinger Decl. (Doc. 701) Ex. 1 at 19-20; Menninger Decl. Ex. C. She testified also that she is not represented by Meredith Schultz, though Ms. Schultz entered her appearance on Ms. Ransome’s behalf. Compare Pottinger Decl. Ex. 1 at 23 with Docket, 17-cv-00616. 2