American Freedom Defense Initiative et al v. Suburban Mobility Authority For Regional Transportation (SMART) et al
Filing
50
MOTION to Compel Discovery by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1--Declaration of Robert J. Muise, # 3 Exhibit A--Plaintiffs' First Request for Production of Documents, # 4 Exhibit B--Defendants' response to Plaintiffs' First Request for Production of Documents and Certificate of Service, # 5 Exhibit C--Sample of emails produced by Defendants in response to Plaintiffs' First Request for Production of Documents, # 6 Exhibit D--Excerpts of the Deposition of SMART, # 7 Exhibit E--Email correspondence between and among counsel for the parties, # 8 Exhibit F--Privilege log produced by Defendants on June 5, 2013, # 9 Exhibit G--Revised privilege log produced by Defendants on June 11, 2013) (Muise, Robert)
<![CDATA[
EXHIBIT F
AFDI v SMART ‐Defendants' Privilege Log
Type of
communication (i.e.,
Date of creation
email, letter,
memorandum, etc.)
Author
Addressee(s)
CC(s)
Type of Privilege
(Attorney‐Client,
Work‐Product, etc.)
Content
Email
3/17/2009 Chubb, Anthony
Gibbons, Beth
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Email
3/17/2009 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
7/24/2009 Gibbons, Beth
Chubb, Anthony; Gordon, Avery
Dryden, Elizabeth; Brown, Steve Attorney Client
Email
7/24/2009 Gibbons, Beth
Chubb, Anthony; Gordon, Avery
Dryden, Elizabeth; Brown, Steve Attorney Client
Email
7/28/2009 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
7/28/2009 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
7/28/2009 Chubb, Anthony
August, Gary
Attorney Client
Email
7/28/2009 Chubb, Anthony
August, Gary
Attorney Client
Email
7/28/2009 Chubb, Anthony
August, Gary
Attorney Client
Email
7/29/2009 Chubb, Anthony
Gibbons, Beth
Attorney Client
Email
7/29/2009 Chubb, Anthony
Gibbons, Beth
Attorney Client
Email
7/29/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Email
7/29/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Chubb, Anthony
Taylor, Darrell
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn; August, Gary
Gordon, Avery
Attorney Client
Email
7/30/2009 August, Gary
Chubb, Anthony; Thwaites, Karyn
Gordon, Avery
Attorney Client
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn; August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony; August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Email
7/30/2009 Chubb, Anthony
Thwaits, Karyn
August, Gary
Attorney Client
Memorandum
7/31/2009 Zausmer, Kaufman, August,
Caldwell & Taylor
Gordon, Avery
Attorney Client
Email
8/10/2009 Chubb, Anthony
Gibbons, Beth
Attorney Client
Email
8/10/2009 Gibbons, Beth
Chubb, Anthony
Attorney Client
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Email
12/28/2009 Chubb, Anthony
Gordon, Avery
Attorney Client
Email
1/13/2010 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
1/20/2010 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
1/20/2010 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
1/22/2010 Chubb, Anthony
Gordon, Avery
Attorney Client
Email
1/22/2010 Chubb, Anthony
Gordon, Avery
Attorney Client
Email
2/10/2010 Dryden, Elizabeth
Brown, Steve
Gibbons, Beth; Chubb, Anthony; Attorney Client
Gordon, Avery
Email
2/10/2010 Dryden, Elizabeth
Brown, Steve
Gibbons, Beth; Chubb, Anthony; Attorney Client
Gordon, Avery
Email
3/3/2010 Dryden, Elizabeth
Brown, Steve
Gordon, Avery
Attorney Client
Email
3/3/2010 Dryden, Elizabeth
Brown, Steve
Gordon, Avery
Attorney Client
Email
3/12/2010 Dryden, Elizabeth
Gordon, Avery
Email
4/6/2010 Dryden, Elizabeth
Gibbons, Beth; Chubb, Anthony
Gordon, Avery
Attorney Client
Email
4/6/2010 Gibbons, Beth
Dryden, Elizabeth; Chubb, Anthony
Gordon, Avery
Attorney Client
Email
4/7/2010 Chubb, Anthony
Dryden, Elizabeth
Gordon, Avery; Barbret, Fred;
Gibbons, Beth
Attorney Client
Email
4/7/2010 Dryden, Elizabeth
Gibbons, Beth; Chubb, Anthony
Gordon, Avery
Attorney Client
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Email
4/8/2010 Gordon, Avery
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/8/2010 Gordon, Avery
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/8/2010 Gordon, Avery
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/8/2010 Gordon, Avery
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/9/2010 Dryden, Elizabeth
Gordon, Avery; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/9/2010 Dryden, Elizabeth
Gordon, Avery; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/9/2010 Dryden, Elizabeth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/9/2010 Dryden, Elizabeth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/9/2010 Dryden, Elizabeth
Brown, Steve; Fetzer, Jim; Hollis, Richard Gordon, Avery
Attorney Client
Email
4/13/2010 Chubb, Anthony
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/13/2010 Chubb, Anthony
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/13/2010 Dryden, Elizabeth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/13/2010 Chubb, Anthony
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Attorney Client
Email
4/13/2010 Dryden, Elizabeth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Sisson, Mark
Attorney Client
Email
4/13/2010 Chubb, Anthony
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Sisson, Mark
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
Email
5/21/2010 Gordon, Avery
Swatosh, John; Dryden, Elizabeth;
Gibbons, Beth; Brown, Steve
Adams, Truvae
Attorney Client
Communication seeking or giving advice
on legal matter or prepared in
anticipation of litigation
]]>
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?
