Timebase Pty Ltd v. Thomson Corporation, The

Filing 108

Minute Entry for proceedings held before Magistrate Judge Jeanne J. Graham: Motion Hearing held on 11/25/2009 re 100 MOTION for Leave to File A SECOND AMENDED COMPLAINT filed by Timebase Pty Ltd. Order to be issued. (akl)

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Timebase Pty Ltd v. Thomson Corporation, The Trek Bicycle Corporation's Redaction Log For Documents Produced Between 12/08/08 and Present--SECOND REVISED 05/13/09 LeMond Cycling, Inc. v. Trek Bicycle Corporation v. Greg LeMond Case No. 08-1010 (United States District Court, District of Minnesota) Bates No. TREK009592 TREK009602 TREK009604 TREK009610 TREK009619 TREK009620 TREK009621 TREK009623 TREK009624 TREK009631 TREK009633 TREK009634 TREK009643 TREK009656 TREK009658 TREK009660 Dockets.Justia.com Date 06/27/07 Type Email Author Jason Schumacher Recipient(s) Bob Burns CC(s) Description Confidential Client ­ Attorney communication for the purpose of legal advice. Name of Trek attorney who printed out email. Name of Trek attorney who printed out email. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Privilege ACP, WP WP WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP 02/27/07 07/31/06 07/31/06 07/28/06 07/27/06 07/31/06 06/26/06 06/26/06 2006 08/08/06 08/01/06 08/01/06 07/31/06 Email Email Email Email Email Email Email Email Handwritten notes Email Email Email Email John Burke Elisabeth Huber Elisabeth Huber Elisabeth Huber John Burke Elisabeth Huber Dave Maurer Dave Maurer Elisabeth Huber Elisabeth Huber Dan Titus Elisabeth Huber Elisabeth Huber Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Doc. 108 Att. 8 Bates No. TREK009662 TREK009663 TREK009664 TREK009666 TREK009667 TREK009674 TREK009676 TREK009685 TREK009686 TREK009688 TREK009689 TREK009690 TREK009708 TREK009709 TREK009712 TREK009713 TREK009814 TREK009815 Date 07/31/06 07/31/06 07/28/06 07/27/06 07/31/06 06/26/06 06/26/06 07/31/06 07/31/06 07/31/06 07/31/06 07/28/06 06/26/06 07/27/07 07/27/07 04/30/08 04/17/08 04/16/08 Type Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Author Elisabeth Huber Elisabeth Huber Elisabeth Huber John Burke Elisabeth Huber Dave Maurer Dave Maurer Elisabeth Huber Elisabeth Huber Elisabeth Huber Joe Siefkes Elisabeth Huber Elisabeth Huber Jason Schumacher Elisabeth Huber Matthew Elam Paul Moran Roger Bird Recipient(s) Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns CC(s) Description Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice re LeMond comments. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP Malcolm Davies 2 Bates No. TREK009825 TREK009826 TREK009839 TREK009840 TREK009841 TREK009842 TREK009844 TREK009845 TREK009846 TREK009848 TREK009849 TREK009850 TREK009877 TREK009878 TREK009879 TREK009880 TREK009881 TREK009882 Date 04/12/08 04/12/08 04/11/08 04/11/08 04/11/08 04/11/08 04/11/08 04/11/08 04/11/08 04/10/08 04/10/08 04/10/08 04/08/08 04/07/08 04/09/08 04/09/08 04/09/08 04/09/08 Type Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Author John Burke Pete St. Onge John Burke John Burke John Burke John Burke John Burke John Burke John Burke Tricia Burke Matthew Elam Dave Maurer John Burke Paul Moran Drew Axt Drew Axt Drew Axt Drew Axt Recipient(s) Bob Burns Sarah Graham Bob Burns Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Sarah Graham Bob Burns Bob Burns Bob Burns John Burke Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns CC(s) Description Confidential Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice re LeMond comments. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client communication forwarding information for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP Maureen Muldoon 3 Bates No. TREK009883 TREK009884 TREK009885 TREK009886 TREK009887 TREK009888 TREK009889 TREK009890 TREK009891 TREK009892 TREK009893 TREK009894 TREK009895 TREK009895 TREK009896 TREK009897 TREK009898 TREK009899 Date 04/09/08 04/09/08 04/09/08 04/09/08 04/09/08 04/09/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 Type Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Author Drew Axt Drew Axt Drew Axt Dave Maurer Maury Malanaphy John Burke John Burke John Burke John Burke John Burke James Peters Paul Moran Bob Burns Jason McDowell Drew Axt Drew Axt Drew Axt Drew Axt Recipient(s) Bob Burns Bob Burns Bob Burns Paul Moran Pete St. Onge Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Group Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns CC(s) Description Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP 4 Bates No. TREK009900 TREK009901 TREK009902 TREK009903 TREK009904 TREK009905 TREK009906 TREK009907 TREK009908 TREK009909 TREK009910 TREK009911 TREK009912 TREK009913 TREK009914 TREK009917 TREK009918 TREK009919 Date 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/08/08 04/09/08 04/08/08 04/08/08 04/09/08 04/09/08 04/09/08 Type Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Author Chad Price Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach Karl Erbach John Burke Aaron Mock Chad Lockart Michael Browne Drew Axt Drew Axt Recipient(s) Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns CC(s) Description Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP 5 Bates No. TREK009920 TREK009923 TREK009924 TREK009925 TREK009926 TREK009927 TREK010126 TREK010127 TREK010134 TREK010142 TREK010147 TREK010156 TREK010156 TREK010196 TREK010197 TREK010199 TREK010211 TREK010351 Date 04/09/08 04/09/08 04/09/08 04/09/08 04/09/08 04/09/08 07/03/06 04/22/08 1995 10/02/00 07/29/04 11/27/06 11/27/06 Type Email Email Email Email Email Email Email Email Handwritten notes Email Email Email Email Handwritten notes Handwritten notes Handwritten notes Handwritten notes Email Author Drew Axt Drew Axt Drew Axt Drew Axt Drew Axt Drew Axt John Burke Dean Gore Bob Burns Ira Langer Dick Burke Elisabeth Huber Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Ralph Weber Recipient(s) Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns CC(s) Description Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Attorney notes. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP WP ACP, WP ACP, WP ACP, WP ACP, WP WP WP WP WP ACP, WP Denise DeMarb John Burke Bob Burns Lisa Smith Bob Burns Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client communication referencing legal advice provided by Attorney. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney notes. Confidential Attorney notes. Confidential Attorney notes. Confidential Attorney notes. 02/15/08 Bob Burns Confidential Attorney ­ Client communication for the purpose of legal advice. 6 Bates No. TREK010351 TREK010351 TREK010352TREK010353 TREK010352 TREK010352 TREK010352 TREK010357 TREK010365 TREK010365 TREK010366 TREK010367 TREK010367 TREK010368TREK010369 TREK010374 TREK010376 TREK010377 TREK010383 TREK010385 Date 02/15/08 02/17/08 02/15/08 02/15/08 02/15/08 02/15/08 2006 03/01/08 02/27/08 02/27/08 02/25/08 02/25/08 12/07/07 06/16/04 Type Email Email Email Email Email Email Handwritten notes Email Email Email Email Email Email Email Author Bob Burns John Burke John Burke Bob Burns Ralph Weber Bob Burns Bob Burns John Burke Bart Knaggs Lawrence Temple Joe Siefkes Bob Burns Lawrence Temple John Burke Recipient(s) John Burke Bob Burns Bob Burns Ralph Weber Bob Burns Ralph Weber CC(s) Description Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney notes. Confidential Client ­ Attorney communication for the purpose of legal advice. Information not required to be produced by Court's January 16, 2009 Order. Information not required to be produced by Court's January 16, 2009 Order. Information; information not required to be produced by Court's January 16, 2009 Order. Information; information not required to be produced by Court's January 16, 2009 Order. Information; information not required to be produced by Court's January 16, 2009 Order. Confidential Client ­ Attorney communication for the purpose of legal advice. PRODUCED Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP WP ACP, WP Bob Burns Lawrence Temple Lancelot Bart Knaggs Lawrence Temple Lawrence Temple Bob Burns Bob Burns Dick Moran John Burke Dick Moran Bob Burns John Burke Laura Hundley Ritts Laura Hundley Ritts Amy Davison Bob Burns Joe Siefkes Amy Davison ACP, WP 11/02/06 06/25/06 10/17/05 Email Email Email Bob Burns John Burke Bob Burns ACP, WP ACP, WP ACP, WP 7 Bates No. TREK010933 TREK011000 TREK011067TREK011068 TREK011091 TREK011091 TREK011091 TREK 011093 TREK 011096 TREK 011099 TREK 011114 TREK 011116 TREK 011124 TREK 011129 TREK 011144 TREK 011144 TREK 011144 TREK 011147 TREK 011147 Date Type Handwritten notes Email Memo Author Bob Burns Doug Kotulski John Burke Bob Burns Anne Docter Jodi Pluemer Bob Burns Bob Burns Bob Burns Bob Burns John Burke Bob Burns Ira Langer Bob Burns Joe Siefkes John Burke Bob Burns Dick Burke Recipient(s) CC(s) Description Confidential Attorney notes. Privilege WP ACP, WP 09/30/08 Bob Burns Confidential Client ­ Attorney communication for the purpose of legal advice. PRODUCED Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. 05/22/03 05/22/03 05/22/03 11/05/04 11/05/04 11/26/04 07/15/04 12/12/99 05/10/05 05/24/00 09/23/04 09/23/04 09/26/04 10/21/04 10/22/04 Email Email Email Email Email Email Email Email Email Email Email Email Email Email Email Anne Docter Katie Ishmael Bob Burns Katie Ishmael Anne Docter Bob Burns Katie Ishmael Lisa Smith Lisa Smith Lisa Smith John Burke Loren Brown Bob Burns John Burke Dick Moran John Burke Dick Moran Joe Siefkes John Burke Bob Burns Joe Siefkes John Burke Dick Burke Bob Burns John Burke ACP ACP ACP ACP, WP ACP, WP ACP, WP ACP, WP ACP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP Jodi Pluemer Bob Burns John Burke Bob Burns Joe Siefkes Joe Siefkes 8 Bates No. TREK 011149 TREK 011152 TREK011162 TREK011163 TREK011199 TREK011201 TREK011202 TREK011209 TREK011215 TREK011219 TREK011225 TREK011230 TREK011278 TREK011306 TREK011317 TREK011318 TREK011323 TREK011335 Date 11/26/04 2004 2003 2003 10/05/00 2000 12/20/99 2000 2000 1996 05/13/03 08/01/06 1996 1996 1996 1996 2004 2004 Type Email Handwritten notes Handwritten notes Handwritten notes Email Handwritten notes Email Handwritten notes Handwritten notes Handwritten notes Email Email Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Author Bob Burns Bob Burns Bob Burns Bob Burns Ira Langer John Burke's office Anne Docter John Burke's office John Burke's office Joe Siefkes John Burke Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Recipient(s) Lisa Smith CC(s) Description Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney designation of Client recipients of document. Confidential Attorney notes. Confidential Attorney notes. Privilege ACP, WP ACP, WP WP WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP WP ACP, WP ACP, WP Bob Burns Bob Burns Bob Burns Krista Rettig John Burke Bob Burns John Burke Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client designation of Attorney recipient of document. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client designation of Attorney recipient of document. Confidential Client designation of Attorney recipient of document. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Attorney designation of Client recipient of document. Confidential Attorney designation of Client recipients of document. Confidential Attorney notes. Confidential Attorney notes. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipients of document. 9 Bates No. TREK011344 TREK011359 TREK011370 TREK011372 TREK011373 TREK011373 TREK011374 TREK011375 TREK011376 TREK011377 TREK011379 TREK011383 TREK011384 TREK011388 TREK011392 TREK011393 TREK011394 TREK011394 Date 1999 1999 1999 1999 7/23/99 7/23/99 1999 7/15/99 1999 1999 1999 1999 1999 1997 1997 09/22/97 09/19/97 09/19/97 Type Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Handwritten notes Email Email Email Author Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns Bob Burns John Burke John Burke Bob Burns Recipient(s) CC(s) Description Confidential Attorney designation of Client recipients of document and Attorney notes. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipient of document. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipients of document. Confidential Attorney notes. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipients of document and Attorney notes. Confidential Attorney notes. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipients of document and Attorney notes. Confidential Attorney notes. Confidential Attorney designation of Client recipient of document and Attorney notes. Confidential Attorney designation of Client recipients of document. Confidential Attorney designation of Client recipient of document and Attorney notes. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP WP ACP, WP ACP, WP WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP Bob Burns Joe Siefkes Bob Burns Joe Siefkes John Burke Joe Siefkes 10 Bates No. TREK011394 TREK011394 TREK011430 TREK011432 TREK011432 TREK011433 TREK011465 TREK011467 TREK011479 TREK011479 TREK011516 TREK011519 TREK011522 TREK011789 TREK011790 TREK011791 TREK011792 TREK011793 TREK011794 TREK011795 TREK011796 TREK011797 TREK011798 Date 09/19/97 Undated 03/06/07 09/06/06 09/06/06 08/23/06 04/07/08 04/02/08 03/20/08 03/20/08 08/22/95 09/08/95 09/13/95 Type Email Email Email Email Email Email Email Email Email Email Handwritten notes Handwritten notes Handwritten notes Author John Burke Bob Burns John Burke Bob Burns John Burke Dean Gore Elisabeth Huber John Burke Dan Titus Elisabeth Huber John Burke John Burke John Burke Recipient(s) Bob Burns Joe Siefkes Bob Burns John Burke Dick Moran Malcolm Davies Bob Burns Bob Burns Bob Burns Bob Burns Elisabeth Huber Bob Burns Bob Burns CC(s) Description Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney ­ Client communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client notes referencing Attorney ­ Client communication for the purpose of legal advice. Confidential Client notes referencing Attorney ­ Client communication for the purpose of legal advice. Confidential Client notes referencing Attorney ­ Client communication for the purpose of legal advice. PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED PRODUCED Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP ACP ACP 11 Bates No. TREK011799 TREK011800 TREK011801 TREK011802 TREK011867 TREK011872 TREK011875 TREK011885 TREK011973 TREK011973 TREK011973 Date Type Author Recipient(s) CC(s) Description PRODUCED PRODUCED PRODUCED PRODUCED Confidential Attorney designation of Client recipient of document and Attorney notes. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Privilege 5/17/99 02/08/00 03/16/00 Handwritten notes Email Email Bob Burns Joe Siefkes Ira Langer Bob Burns Bob Burns Dean Gore Gene DiMenna Bob Burns Sarah Graham Ralph Weber R. Hinkle Emily Zastrow Christopher Dombrowicki Kristal Stippich Joan Latawiec Bob Burns Ralph Weber Christopher Dombrowicki Joan Latawiec Dan Titus ACP, WP ACP, WP ACP, WP 04/15/08 04/15/08 12/20/08 Email Email Email Andrew Young Bob Burns Ralph Weber PRODUCED Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential Attorney communication forwarding information for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. ACP, WP ACP, WP ACP, WP TREK011977 TREK011977 TREK011977 TREK012167 TREK012169 TREK012169 12/22/08 12/22/08 12/22/08 Email Email Email Handwritten notes Email Email Jason Schumacher Bob Burns Ralph Weber Bob Burns Maureen Muldoon Bob Burns Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential Attorney notes. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. ACP, WP ACP, WP ACP, WP WP ACP, WP ACP, WP 01/08/09 01/08/09 Bob Burns Ralph Weber Christopher Dombrowicki 12 Bates No. TREK012169 TREK012169 TREK012177 TREK012177 TREK012177 TREK012177 TREK012180 TREK012180 TREK012180 TREK012197 TREK012200TREK012203 TREK013357 TREK013848 TREK013854 TREK013854 TREK013856 TREK013865 TREK013868 Date 01/08/09 01/08/09 01/08/09 01/08/09 01/08/09 01/08/09 01/08/09 01/08/09 01/08/09 12/24/08 Type Email Email Email Email Email Email Email Email Email Email Author Ralph Weber Joan Latawiec Maureen Muldoon Bob Burns Ralph Weber Joan Latawiec Bob Burns Ralph Weber Joan Latawiec Laurie Koch Recipient(s) Joan Latawiec Kristal Stippich Emily Zastrow Bob Burns Ralph Weber Christopher Dombrowicki Joan Latawiec Kristal Stippich Emily Zastrow Ralph Weber Christopher Dombrowicki Joan Latawiec Kristal Stippich Emily Zastrow Mark Joslyn CC(s) Description Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Client ­ Attorney forwarding communication for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential communication between employees of Outside Counsel for the purpose of legal advice. Confidential Client ­ Attorney communication for the purpose of legal advice. Credit card information. Confidential Attorney notes. Privilege ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP Bob Burns 12/2004 07/22/04 Handwritten notes Email Notes Notes Notes Bob Burns Dean Gore Bob Burns Bob Burns Joe Vadeboncoeur ACP, WP WP ACP, WP ACP, WP WP WP Name of Trek attorney who printed email. Confidential Client ­ Attorney communication for the purpose of legal advice. Confidential Attorney notes. Attorney address information. Confidential Attorney handwritten notes. Confidential Attorney handwritten notes. 13

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