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)
EXHIBIT G
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
Legal opinion about unrelated
advertisement
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
Communication requesting advice on
unrelated advertisement
Communication requesting advice on
unrelated advertisement
Duplicate
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
Email
7/29/2009 Chubb, Anthony
7/29/2009 Thwaites, Karyn
Gibbons, Beth
Chubb, Anthony
August, Gary
Attorney Client
Attorney Client
Email
7/29/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Analysis by outside counsel concerning
unrelated advertisement
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Request for analysis of unrelated
advertisement by outside counsel
Analysis by outside counsel concerning
unrelated advertisement
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Chubb, Anthony
Taylor, Darrell
Attorney Client
Legal opinion about unrelated
advertisement
Communication requesting advice on
unrelated advertisement
Request for analysis of unrelated
advertisement by outside counsel
Request for analysis of unrelated
advertisement by outside counsel
Request for analysis of unrelated
advertisement by outside counsel
Legal opinion about unrelated
advertisement
Duplicate
Analysis by outside counsel concerning
unrelated advertisement
Request for analysis of unrelated
advertisement by outside counsel
Communication informing department
head of referral of review of unrelated
advertisement to outside counsel
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn; August, Gary
Gordon, Avery
Attorney Client
Request for analysis of unrelated
advertisement by outside counsel
Analysis by outside counsel concerning
unrelated advertisement
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
Analysis by outside counsel concerning
unrelated advertisement
Email
7/30/2009 Chubb, Anthony
Thwaites, Karyn
August, Gary
Attorney Client
Email
7/30/2009 Thwaites, Karyn
Chubb, Anthony
August, Gary
Attorney Client
Request for analysis of unrelated
advertisement by outside counsel
Analysis by outside counsel concerning
unrelated advertisement
Email
7/30/2009 Chubb, Anthony
Thwaits, Karyn
August, Gary
Attorney Client
Analysis by outside counsel concerning
unrelated advertisement
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
Memorandum offering legal opinion on
unrelated advertisement from outside
counsel
Legal opinion about unrelated
advertisement
Communication following up on July 29,
2009 email and requesting advice
Email
Email
12/28/2009 Chubb, Anthony
1/13/2010 Gibbons, Beth
Gordon, Avery
Chubb, Anthony
Attorney Client
Attorney Client
Email
1/20/2010 Gibbons, Beth
Chubb, Anthony
Attorney Client
Email
Email
1/20/2010 Gibbons, Beth
1/22/2010 Chubb, Anthony
Chubb, Anthony
Gordon, Avery
Attorney Client
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
Request for analysis of unrelated
advertisement by outside counsel
Analysis by outside counsel concerning
unrelated advertisement
Analysis of legal billing
Communication providing additional
information to legal for analysis of
unrelated advertisement
Communication requesting advice on
unrelated advertisement
Duplicate
Analysis of content and policy applicable
to unrelated advertisement
Legal analysis and attorney mental
impressions concerning unrelated
advertisement
Communication requesting advice and
reporting legal opinions on unrelated
advertisement
Duplicate
Email
3/3/2010 Dryden, Elizabeth
Brown, Steve
Gordon, Avery
Attorney Client
Email
Email
3/3/2010 Dryden, Elizabeth
3/12/2010 Dryden, Elizabeth
Brown, Steve
Gordon, Avery
Gordon, Avery
Attorney Client
Attorney Client
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
Communication concerning legal
analysis of need for advertising policy
Email
4/8/2010 Gordon, Avery
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Attorney Client
Email
4/8/2010 Gordon, Avery
Attorney Client
Email
4/8/2010 Gordon, Avery
Attorney Client
Duplicate
Email
4/8/2010 Gordon, Avery
Attorney Client
Duplicate
Email
4/9/2010 Dryden, Elizabeth
Attorney Client
Previously produced ‐ listed in error
Email
4/9/2010 Dryden, Elizabeth
Attorney Client
Duplicate
Email
4/9/2010 Dryden, Elizabeth
Attorney Client
Duplicate
Email
4/9/2010 Dryden, Elizabeth
Attorney Client
Duplicate
Email
4/9/2010 Dryden, Elizabeth
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Dryden, Elizabeth; Gibbons, Beth; Chubb,
Anthony
Gordon, Avery; Gibbons, Beth; Chubb,
Anthony
Gordon, Avery; Gibbons, Beth; Chubb,
Anthony
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Brown, Steve; Fetzer, Jim; Hollis, Richard Gordon, Avery
Communication clarifying nature and
extent of review being requested by
legal department of unrelated
advertisement
Duplicate
Attorney Client
Communication concerning legal
opinion about advertising policy and
board action
Communication requesting advice on
Leaving Islam advertisement
Legal analysis and attorney mental
impressions concerning Leaving Islam
advertisement
Previously produced ‐ listed in error
Email
4/12/2010 Beth Gibbons
Anthony Chubb
Attorney Client
Email
4/12/2010 Chubb, Anthony
Gordon, Avery
Attorney Client
Email
4/13/2010 Chubb, Anthony
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Attorney Client
Communication requesting advice and
reporting legal opinions on unrelated
advertisement
Duplicate
Communication responding to request
by attorney for additional information
on unrelated advertisement
Communication requesting advice on
unrelated advertisement
Communication requesting advice on
unrelated advertisement
Communication concerning legal
analysis of need for advertising policy
Email
4/13/2010 Chubb, Anthony
Email
4/13/2010 Dryden, Elizabeth
Email
4/13/2010 Chubb, Anthony
Email
4/13/2010 Dryden, Elizabeth
Email
4/13/2010 Chubb, Anthony
Email
5/21/2010 Gordon, Avery
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Chubb, Anthony; Gordon, Avery;
Gibbons, Beth
Dryden, Elizabeth; Gordon, Avery;
Gibbons, Beth
Swatosh, John; Dryden, Elizabeth;
Gibbons, Beth; Brown, Steve
Attorney Client
Duplicate
Attorney Client
Communication requesting advice on
unrelated advertisement
Duplicate
Attorney Client
Sisson, Mark
Attorney Client
Sisson, Mark
Attorney Client
Adams, Truvae
Attorney Client
Communication requesting advice on
unrelated advertisement
Legal opinion about unrelated
advertisement
Legal opinion about Leaving Islam
advertisement
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