gov.uscourts.nysd.447706.156.3.pdf

Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 1 of 9 EXHIBIT C  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 2 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type [email protected],br AC Privilege and a Work Product/joint 2/16/2015 [email protected],robiej defense/common 2 1:05 [email protected] [email protected] Discussion of evidence among client and attorneys interest Withheld 2 msg [email protected],bra [email protected],cassel AC Privilege and l Work Product/joint 2/21/2015 [email protected],robiejenna [email protected] defense/common 7 16:45 Sigrid McCawley [email protected] om Discussion of evidence among client and attorneys interest Withheld 2 msg [email protected] AC Privilege and m,cassellp@l Work Product/joint 2/21/2015 aw.utah.edu,robiejenn defense/common 9 17:05 Brad Edwards [email protected] [email protected] om Discussion of evidence among client and attorneys interest Withheld 2 msg [email protected] m,brad@pat AC Privilege and htojustice.com, Work Product/joint 2/23/2015 [email protected]. Discussion of thoughts and impressions of defense/common 12 14:21 Sigrid McCawley [email protected] edu attorneys interest Withheld 1 msg AC Privilege and [email protected] Work Product/joint 2/23/2015 [email protected],ro m,cassellp@ Discussion of thoughts and impressions of defense/common 13 14:29 [email protected] [email protected] law.utah.edu attorneys interest Withheld 1 msg [email protected] m,brad@pat AC Privilege and htojustice.com, Work Product/joint 2/23/2015 [email protected]. Discussion of thoughts and impressions of defense/common 14 16:01 Virginia Giuffre [email protected] edu attorneys interest Withheld 1 msg AC Privilege and [email protected] Email chain with Giuffre, Edwards, McCawley, Work Product/joint 3/13/2015 om,brad@pat Henderson and Pottinger re legal advice on media defense/common 20 17:29 Stan Pottinger [email protected] htojustice.com issues interest Withheld 2 msg AC Privilege and Work Product/joint 3/13/2015 Email chain with Giuffre, Edwards, McCawley and defense/common 21 17:49 Virginia Giuffre [email protected] Pottinger re legal advice on media issues interest Withheld 2 msg AC Privilege and [email protected] Email chain with Giuffre, Edwards, McCawley, Work Product/joint 3/13/2015 om,brad@pat Henderson and Pottinger re legal advice on media defense/common 22 17:56 [email protected] [email protected] htojustice.com issues interest Withheld 3 msg  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 3 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type AC Privilege and Email chain with Giuffre, Edwards, McCawley, Work Product/joint 3/13/2015 [email protected],rob [email protected] Henderson and Pottinger re legal advice on media defense/common 23 18:00 Brad Edwards i [email protected] om issues interest Withheld 3 msg AC Privilege and Email chain with Giuffre, Edwards, McCawley, Work Product/joint 3/13/2015 Henderson and Pottinger re legal advice on media defense/common 25 18:25 Virginia Giuffre [email protected] issues interest Withheld 3 msg Attorney Client/joint defense/common 3/17/2015 Email chain with Giuffre, Edwards, Pottinger and interest/work 31 19:42 Virginia Giuffre [email protected] McCawley re legal advice related to VRS product Withheld 1 msg Attorney Client/joint [email protected],ro [email protected],br Email chain with Giuffre, Edwards, Henderson, defense/common 3/20/2015 [email protected],stan ittany@path Pottinger, McCawley and BSF staff re legal advice interest/work 32 15:43 Sigrid McCawley [email protected] tojustice.com related to VRS product Withheld 1 msg Attorney Client/joint [email protected],bra brittany@pathtojustic Email chain with Giuffre, Edwards, Henderson, defense/common 4/9/2015 [email protected],robiej e.com,sperki McCawley and BSF staff re legal advice re media interest/work 49 7:16 Sigrid McCawley [email protected] [email protected] issues product Withheld 2 msg Attorney Client/joint [email protected] defense/common 4/10/2015 m,brad@pat interest/work 56 14:59 Sigrid McCawley [email protected] htojustice.com Providing legal advice re media issues product Withheld 1 msg [email protected] m,brad@pat htojustice.com, AC Privilege and brittany@pathtojus Email chain with Giuffre, McCawley, Henderson, Work Product/joint 4/10/2015 tice.com,eperez@BSFL Edwards, Pottinger and legal assistant re legal defense/common 58 17:31 Sigrid McCawley [email protected] LP.com documents, with attachments interest Withheld 2 msg AC Privilege and [email protected] Email chain with Giuffre, Pottinger, Edwards and Work Product/joint 4/13/2015 m,brad@pat McCawley re legal advice regarding potential defense/common 69 13:52 Sigrid McCawley [email protected] htojustice.com public statements interest Withheld 3 msg  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 4 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type [email protected],br Attorney i Client/joint [email protected],ro defense/common 4/14/2015 [email protected],stan interest/work 71 23:38 Brad Edwards [email protected] Providing legal advice related to VRS product Withheld 1 msg Attorney Client/joint defense/common 7/29/2015 [email protected] interest/work 99 19:45 Sigrid McCawley [email protected] m Conveying legal advice on media issues product Withheld 1 msg Attorney Client/joint [email protected],ro Email chain with Giuffre, Edwards, Pottinger and defense/common 9/7/2015 [email protected],stan McCawley re collection of information to assist in interest/work 109 18:58 Sigrid McCawley [email protected] providing legal advice re potential litigation product Withheld 1 msg  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 5 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action 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 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 Virginia Giuffre, Brad of Florida. Documents withheld pursuant to the Edwards, Paul Cassell, Virginia Giuffre, Brad privileges asserted included communications from Brittany Henderson (and Edwards, Paul Cassell, Ms. Giuffre to the attorneys listed seeking legal other , Sigrid McCawley, Brittany Henderson, Sigrid advice related to the CVRA case, communications Meredith Schultz, David McCawley, Meredith from the attorneys to Ms. Giuffre giving legal Appro Emails, Boies, Jack Scarola, Stan Schultz, David Boies, Jack advice or giving attorney mental impressions x. 1.3K letters, and Pottinger, Ellen Brockman, Scarola, Stan Pottinger, related to the CVRA case, communications sending docs other Legal Assistants, Ellen Brockman, Legal or attaching attorney work product related to the overla communicat Professionals retained by Assistants, Professionals CVRA case, and/or communications sending or AC Privilege and pping ions from attorneys to aid in the retained by attorneys to aid attaching client revisions to attorney work product Work Product/joint with 2011 ‐ rendition of legal advice in the rendition of legal related to the CVRA case, and communications re defense/common other 125 Present and representation advice and representation evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 6 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action 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 that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Giuffre v. Maxwell (“Maxwell case”), 15‐cv‐07433‐RWS, pending in the Southern District of New York, since the date Virginia Giuffre, Brad of filing, September 21, 2015. Documents Edwards, Paul Cassell, Virginia Giuffre, Brad withheld pursuant to the privileges asserted Brittany Henderson, Sigrid Edwards, Paul Cassell, included communications from Ms. Giuffre to the McCawley, Meredith Brittany Henderson, Sigrid attorneys listed seeking legal advice related to the Schultz, David Boies, McCawley, Meredith Maxwell case, communications from the attorneys Appro Emails, Stephen Zach, Stan Schultz, David Boies, to Ms. Giuffre giving legal advice or giving attorney x. 1.3K letters, and Pottinger, Ellen Brockman, Stephen Zach, Stan mental impressions related to the Maxwell case, docs other Legal Assistants, Pottinger, Ellen Brockman, communications sending or attaching attorney overla communicat Professionals retained by Legal Assistants, work product related to the Maxwell case, and/or AC Privilege and pping ions from attorneys to aid in the Professionals retained by communications sending or attaching client Work Product/joint with 9/21/15 ‐ rendition of legal advice attorneys to aid in the revisions to attorney work product related to the defense/common other 126 Present and representation rendition of legal advice and Maxwell case, and communications re evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 7 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action 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 that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re:Bradley Edwards and Paul Cassell v. Alan Dershowitz(“Dershowitz case”), Case no. 15000072, pending in the Seventeenth Judicial Circuit, Broward County, Virginia Giuffre, Brad Florida. Documents withheld pursuant to the Edwards, Paul Cassell, Virginia Giuffre, Brad privileges asserted included communications from Brittany Henderson, Sigrid Edwards, Paul Cassell, Ms. Giuffre to the attorneys listed seeking legal McCawley, Meredith Brittany Henderson, Sigrid advice related to the Dershowitz case, Emails, Schultz, David Boies, McCawley, Meredith communications from the attorneys to Ms. Giuffre Appro letters, and Stephen Zach, Stan Schultz, David Boies, giving legal advice or giving attorney mental x. 1.3K other Pottinger, Ellen Brockman, Stephen Zach, Stan impressions related to the Dershowitz case, docs communicat Legal Assistants, Pottinger, Ellen Brockman, communications sending or attaching attorney overla ions from Professionals retained by Legal Assistants, work product related to the Dershowitz case, AC Privilege and pping January attorneys to aid in the Professionals retained by and/or communications sending or attaching Work Product/joint with 2015 ‐ rendition of legal advice attorneys to aid in the client revisions to attorney work product related defense/common other 127 Present and representation rendition of legal advice and to the Dershowitz case, and communications re interest Withheld cases [email protected], [email protected],rob brad@patht Email chain with Giuffre, McCawley, Edwards, 140 2/11/2016 Sigrid McCawley i [email protected] ojustice.com Pottinger and BSF staff re media communications. Attorney Client Redacted 3 msg [email protected], Smccawley @BSFLLP.com, brad@pathtojustice. Email chain with Giuffre, McCawley, Edwards, 141 2/11/2016 [email protected] [email protected] com Pottinger and BSF staff re media communications. Attorney Client Redacted 3 msg Email chain with Giuffre and Pottinger re media 142 2/9/2016 [email protected] [email protected] communications. Attorney Client Redacted 2 msg Email chain with Giuffre and Pottinger re media 149 2/11/2015 Virginia Giuffre [email protected] communications Attorney Client Redacted 3 msg Email chain with Pottinger and Giuffre re AC Privilege and 151 1/13/2015 Virginia Giuffre [email protected] anticipated litigation. Work Product Withheld 1 msg  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 8 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action 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 that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule26.2(c). This categorical entry is regarding correspondencere potential legal action against entities and individuals. Documents withheld pursuant to the privileges asserted included Virginia Giuffre, Brad Virginia Giuffre, Brad communications from Ms. Giuffre to the attorneys Edwards, Paul Cassell, Edwards, Paul Cassell, listed seeking legal advice related to potential law Brittany Henderson, Sigrid Brittany Henderson, Sigrid suits, communications from the attorneys to Ms. Emails, McCawley, Meredith McCawley, Meredith Giuffre giving legal advice or giving attorney letters, and Schultz, David Boies, Schultz, David Boies, mental impressions related to the law suits, Appro other Stephen Zach, Stan Stephen Zach, Stan communications sending or attaching attorney x. 1.3K communicat Pottinger, Ellen Brockman, Pottinger, Ellen Brockman, work product related to potential lawsuits, and/or overla ions from Legal Assistants, Legal Assistants, communications sending or attaching client AC Privilege and pping January Professionals retained by Professionals retained by revisions to attorney work product related to Work Product/joint with 2015 ‐ attorneys to aid in the attorneys to aid in the potential lawsuits, and communications re defense/common other 152 Present rendition of legal advice rendition of legal advice evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 9 of 9 Pottinger Documents Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action 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 The law enforcement a heavy burden on Plaintiff that outweighs its entity, Virginia Giuffre, The law enforcement entity, benefit. Therefore, Plaintiff has employed Email and David Boies, Stan Virginia Giuffre, David categorical logging pursuant to Local Civil approx letter Pottinger, Sigrid Boies, Stan Pottinger, Sigrid Rule26.2(c). This categorical entry is regarding . 57 communicat McCawley, Paul Cassell, McCawley, Paul Cassell, correspondence the currently ongoing criminal docum 153 ions Brad Edwards Brad Edwards investigation of Defendant and others. Public Interest Withheld ents