American Freedom Defense Initiative et al v. Suburban Mobility Authority For Regional Transportation (SMART) et al

Filing 52

RESPONSE to 50 MOTION to Compel Discovery filed by Beth Gibbons, John Hertel, Suburban Mobility Authority For Regional Transportation (SMART). (Attachments: # 1 Index of Exhibits, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B, # 4 Exhibit Exhibit C, # 5 Exhibit Exhibit D, # 6 Exhibit Exhibit E, # 7 Exhibit Exhibit F) (Hildebrandt, Christian)

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AFDI v SMART -Defendants' Privilege Log Type of communication (i.e., email, letter, memorandum, etc.) Date of creation 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 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 Request for analysis of unrelated advertisement by outside counsel Analysis by outside counsel concerning unrelated advertisement 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 Email 2/10/2010 Dryden, Elizabeth Brown, Steve Gibbons, Beth; Chubb, Anthony; Attorney Client Gordon, Avery Gordon, Avery Attorney Client Email 3/3/2010 Dryden, Elizabeth Brown, Steve 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 Communication clarifying nature and extent of review being requested by legal department of unrelated advertisement Email 4/8/2010 Gordon, Avery Attorney Client Duplicate 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 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 Email 4/12/2010 Beth Gibbons Anthony Chubb Attorney Client Email 4/12/2010 Chubb, Anthony Gordon, Avery Attorney Client Duplicate 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 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 Dryden, Elizabeth; Gordon, Avery; Gibbons, Beth Chubb, Anthony; Gordon, Avery; Gibbons, Beth Dryden, Elizabeth; Gordon, Avery; Gibbons, Beth Chubb, Anthony; Gordon, Avery; Gibbons, Sisson, Mark Beth Dryden, Elizabeth; Gordon, Avery; Sisson, Mark Gibbons, Beth Swatosh, John; Dryden, Elizabeth; Adams, Truvae Gibbons, Beth; Brown, Steve Attorney Client Previously produced - listed in error Attorney Client Duplicate Attorney Client Communication requesting advice on unrelated advertisement Duplicate Attorney Client Attorney Client Attorney Client Attorney Client Communication requesting advice on unrelated advertisement Legal opinion about unrelated advertisement Legal opinion about Leaving Islam advertisement

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