Drummond Special Master R&R On Crime Fraud in Camera Review Exhibit B R 633-2

Case 2:11-cv-03695-RDP Document 633-2 Filed 06/01/20 Page 1 of 17 FILED
2020 Jun-01 AM 10:29

U.S. DISTRICT COURT
N.D. OF ALABAMA
Bates
CRIME/FRAUD "closely Priv Doc
Related to Number - if
ASSERTED related to" or "in COMMENTS/ Modified
No. DOC NUMBER DOC STATUS RECOMMENDATION RFPD Date Author Recipient Copied Defs' Description Document Produced in
PRIVILEGE furtherance of" (if ANALYSIS Since Prior
Number Redacted
applicable) Log?
Form
Ledger of C&S expenses; entries reflecting

payments to Colombian intermediary who
Redacted information reflecting
facilitated payments to witnesses are
Gilma Yineth Baeza Acosta's
Witness Bribery; Suborning closely related to or in furtherance of the
20 CSPRIV400081 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 12/18/2009 C&S Accounting C&S Accounting reimbursement request for
Perjury alleged crimes of witness bribery and
expenses incurred to pursue
suborning perjury and should be produced;
litigation against Drummond.
remainder should be redacted as work
product
Ledger of C&S expenses, internal C&S
email communications, and confirmation
of payments; portions pertaining to Redacted information reflecting
payments made to co-counsel for Dr. Pedro Mahecha, Esq.'s
Witness Bribery; Suborning
22 CSPRIV400085 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 1-64; 1-65; 01/29/2010 C&S Accounting C&S Accounting reimbursement request for
Perjury
or in furtherance of the alleged crimes of expenses incurred to pursue
witness bribery and suborning perjury and litigation against Drummond.
should be produced; remainder should be
redacted as work product
Internal C&S communication and

confirmation of payments; portions Documents reflecting Ivan Otero
reflecting or discussing wire payments to Esq.'s reimbursement request for
Ivan Otero for security and payments for expenses incurred to pursue
126 CSPRIV400480 AWP Withheld Crime-Fraud Exception Colombian witnesses are closely related to 1-64; 1-65; 04/20/2011 C&S Accounting C&S Accounting litigation against Drummond,
Perjury
or in furtherance of the alleged crimes of including redacted entries related
witness bribery and suborning perjury and to work performed in anticipation
should be produced; remainder should be for litigation.
Internal C&S communication; portions

discussing or reflecting wire payments
made for Colombian witnesses are closely
related to or in furtherance of the alleged Redacted documents reflecting
Witness Bribery; Suborning crimes of witness bribery and suborning expenses Conrad & Scherer's
130 CSPRIV400493 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 05/04/2011 C&S Accounting C&S Accounting
Perjury perjury and should be produced; expenses incurred in pursuing
remainder should be redacted as work litigation against Drummond.
product; document provided to the Special
Master contains redactions for non-
responsiveness
responsiveness
responsiveness
related to or in furtherance of the alleged Redacted email reflecting Conrad
Witness Bribery; Suborning crimes of witness bribery and suborning & Scherer's expenses incurred in
Perjury perjury and should be produced; pursuing litigation against
remainder should be redacted as work Drummond.
responsiveness
related to or in furtherance of the alleged Redacted email reflecting Conrad
Witness Bribery; Suborning crimes of witness bribery and suborning & Scherer's expenses incurred in
Perjury perjury and should be produced; pursuing litigation against
remainder should be redacted as work Drummond.
responsiveness
made for Colombian witnesses and
monthly wire payments to Ivan Otero are Redacted e-mail reflecting
closely related to or in furtherance of the Francisco Ramirez's
160 CSPRIV400610 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 06/27/2011 C&S Accounting C&S Accounting reimbursement request for
Perjury
suborning perjury and should be produced; expenses incurred to pursue
responsiveness
Redacted email and information
monthly wire payments to Ivan Otero are
reflecting Francisco Ramirez
closely related to or in furtherance of the
Witness Bribery; Suborning Terrance Cuellar, Esq.'s monthly wire
161 CSPRIV400614 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 06/28/2011 Victoria Ryan
Perjury Collingsworth transfer for retainer fee incurred in
pursuing litigation against
Drummond.
responsiveness
made for Colombian witnesses and Redacted e-mail reflecting Conrad
monthly wire payments to Ivan Otero are & Scherer's expenses incurred in
closely related to or in furtherance of the pursuing litigation against
174 CSPRIV400658 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 08/04/2011 C&S Accounting C&S Accounting Drummond and Francisco
Perjury
suborning perjury and should be produced; Ramirez's monthly retainer fee
remainder should be redacted as work incurred in pursuing litigation
product; document provided to the Special against Drummond.
responsiveness
Case 2:11-cv-03695-RDP Document 633-2 Filed 06/01/20 Page 2 of 17
Bates
Number Redacted
applicable) Log?
Form
Documents reflecting Conrad &
Scherer's expenses incurred and
Ivan Otero, Esq.'s reimbursement
Witness Bribery; Suborning request for expenses incurred to
178 CSPRIV400678 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 08/05/2011 Victoria Ryan Lorraine Sarfati
Perjury pursue litigation against
Drummond, including descriptions
related to work performed in
anticipation of litigation.
responsiveness
Timesheet for C&S attorney; entries Redacted privileged time entries of
Witness Bribery; Suborning reflecting organization of or follow-up on 1-64; 1-65; 1- Lorraine Leete regarding work
182 CSPRIV400691 AWP Withheld Crime-Fraud Exception 05/31/2011 Lorraine Leete C&S Accounting
Perjury security payments for Colombian 71; performed in anticipation of
witnesses and for Ivan Otero litigation.
discussing or reflecting wire payments Redacted email and documents
made for Colombian witnesses and reflecting expenses incurred by
Terrence
monthly wire payments to Ivan Otero are C&S in pursuing litigation against
Collingsworth;
closely related to or in furtherance of the Drummond, including information
Witness Bribery; Suborning Terrence Catherine
187 CSPRIV400718 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 08/23/2011 Victoria Ryan reflecting Francisco Ramirez
Perjury Collingsworth Salomon;
suborning perjury and should be produced; Cuellar, Esq.'s monthly wire
Janette Perez;
remainder should be redacted as work transfer for retainer fee incurred in
Lorraine Sarfati
product; document provided to the Special pursuing litigation against
Master contains redactions for non- Drummond.
responsiveness
Terrence
Collingsworth;
Janette Perez;
Lorraine Sarfati
responsiveness
Terrence
Collingsworth;
Janette Perez;
Lorraine Sarfati
responsiveness
made for Colombian witnesses and Redacted document reflecting
monthly wire payments to Ivan Otero are Conrad & Scherer's expenses
closely related to or in furtherance of the incurred in pursuing litigation
203 CSPRIV400832 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 11/02/2011 C&S Accounting C&S Accounting against Drummond, including
Perjury
suborning perjury and should be produced; information reflecting Francisco
remainder should be redacted as work Ramirez monthly wire for retainer
product; document provided to the Special fee.
responsiveness

discussing or reflecting monthly wire
payments to Ivan Otero are closely related Maggie Crosby;
Redacted email reflecting Conrad
to or in furtherance of the alleged crimes Janette Perez;
Witness Bribery; Suborning Terrence & Scherer's expenses incurred in
214 CSPRIV400873 AWP Withheld Crime-Fraud Exception of witness bribery and suborning perjury 1-64; 1-65; 10/25/2011 Ty
Perjury Collingsworth pursuing litigation against
and should be produced; remainder should Allmandinger;
Drummond.
be redacted as work product; document Lorraine Sarfati
provided to the Special Master contains
redactions for non-responsiveness

& Scherer's expenses incurred in
related to or in furtherance of the alleged
Drummond and contains
Witness Bribery; Suborning crimes of witness bribery and suborning
217 CSPRIV400883 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 11/02/2011 C&S Accounting C&S Accounting information related to Francisco
Perjury perjury and should be produced;
Ramirez Cuellar, Esq.'s monthly
wire transfer for retainer fee
incurred in pursuing litigation
against Drummond.
responsiveness
discussing or reflecting wire payments Redacted document reflecting
made for Colombian witnesses and Conrad & Scherer's expenses
monthly wire payments to Ivan Otero are incurred in pursuing litigation
closely related to or in furtherance of the against Drummond and redacted
220 CSPRIV400891 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 12/01/2011 C&S Accounting C&S Accounting information containing Francisco
Perjury
suborning perjury and should be produced; Ramirez Cuellar, Esq.'s monthly
remainder should be redacted as work wire transfer for retainer fee
product; document provided to the Special incurred in pursuing litigation
Master contains redactions for non- against Drummond.
responsiveness
monthly wire payments to Ivan Otero are Maggie Crosby,
Redacted email reflecting
closely related to or in furtherance of the Ty
Witness Bribery; Suborning Terrence reimbursement requests for
234 CSPRIV400970 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 11/29/2011 Allmandinger,
Perjury Collingsworth expenses incurred in pursuing
suborning perjury and should be produced; Catherine
remainder should be redacted as work Salomon
responsiveness
monthly wire payments to Ivan Otero are Maggie Crosby,
Redacted email reflecting
closely related to or in furtherance of the Ty
Witness Bribery; Suborning Terrence reimbursement requests for
235 CSPRIV400973 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 11/29/2011 Allmandinger,
Perjury Collingsworth expenses incurred in pursuing
suborning perjury and should be produced; Catherine
remainder should be redacted as work Salomon
responsiveness
Bates
Number Redacted
applicable) Log?
Form

payments to Ivan Otero are closely related
Ty Redacted email reflecting
to or in furtherance of the alleged crimes
Witness Bribery; Suborning Terrence Allmandinger, reimbursement requests for
238 CSPRIV400982 AWP Withheld Crime-Fraud Exception of witness bribery and suborning perjury 1-64; 1-65; 01/25/2012 Maggie Crosby
Perjury Collingsworth Catherine expenses incurred in pursuing
and should be produced; remainder should
Salomon litigation against Drummond.
be redacted as work product; document

discussing or reflecting monthly wire Documents reflecting Francisco
payments to Ivan Otero are closely related Ramirez Cuellar, Esq.'s monthly
to or in furtherance of the alleged crimes wire transfer for retainer fee and
239 CSPRIV400985 AWP Withheld Crime-Fraud Exception of witness bribery and suborning perjury 1-64; 1-65; 02/02/2012 C&S Accounting C&S Accounting redacted information related to
Perjury
and should be produced; remainder should reimbursement requests for
be redacted as work product; document expenses incurred in pursuing
provided to the Special Master contains litigation against Drummond.

payments to Ivan Otero are closely related Redacted documents reflecting
to or in furtherance of the alleged crimes Ivan Otero, Esq.'s request for
248 CSPRIV401036 AWP Withheld Crime-Fraud Exception of witness bribery and suborning perjury 1-64; 1-65; 02/28/2012 C&S Accounting C&S Accounting reimbursement for expenses
Perjury
and should be produced; remainder should incurred in pursuing litigation
be redacted as work product; document against Drummond.

made for Colombian witnesses and Documents reflecting Francisco
monthly wire payments to Ivan Otero are Ramirez Cuellar, Esq.'s monthly
closely related to or in furtherance of the wire transfer for retainer fee and
249 CSPRIV401044 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 02/28/2012 C&S Accounting C&S Accounting redacted information related to
Perjury
suborning perjury and should be produced; other expenses incurred in
remainder should be redacted as work pursuing litigation against
product; document provided to the Special Drummond.
responsiveness

made for Colombian witnesses (or to
Colombian intermediary) and monthly
wire payments to Ivan Otero are closely Janette Perez,
Redacted email reflecting expenses
Witness Bribery; Suborning related to or in furtherance of the alleged Terrence Catherine
250 CSPRIV401047 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 02/21/2012 Maggie Crosby incurred in pursuing litigation
Perjury crimes of witness bribery and suborning Collingsworth Salomon, Ty
against Drummond.
perjury and should be produced; Allmandinger
responsiveness

Scherer's expenses incurred to
pursue litigation against
Drummond, including redacted
Witness Bribery; Suborning information reflecting Francisco
263 CSPRIV401122 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 03/20/2012 C&S Accounting C&S Accounting
Perjury Ramirez Cuellar, Esq.'s monthly
wire transfer for retainer fee and
other expenses incurred in
Drummond.
responsiveness
Drummond.
responsiveness

discussing or reflecting wire payments Documents reflecting Conrad &
made for Colombian witnesses (or to Scherer's expenses incurred to
Colombian intermediary) and monthly pursue litigation against
wire payments to Ivan Otero are closely Drummond, including redacted
Witness Bribery; Suborning related to or in furtherance of the alleged information reflecting Francisco
Perjury crimes of witness bribery and suborning Ramirez Cuellar, Esq.'s monthly
perjury and should be produced; wire transfer for retainer fee and
remainder should be redacted as work other expenses incurred in
responsiveness

Drummond.
responsiveness
discussing or reflecting wire payments Redacted email reflecting Conrad
made for Colombian witnesses and & Scherer's expenses incurred to
monthly wire payments to Ivan Otero are pursue litigation against
285 CSPRIV401302 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 05/04/2012 C&S Accounting C&S Accounting reflecting Francisco Ramirez
Perjury
responsiveness
Bates
Number Redacted
applicable) Log?
Form
discussing or reflecting wire payments Documents and redacted email
made for Colombian witnesses and reflecting Conrad & Scherer's
monthly wire payments to Ivan Otero are expenses incurred to pursue
closely related to or in furtherance of the litigation against Drummond,
286 CSPRIV401306 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 05/04/2012 C&S Accounting C&S Accounting including information reflecting
Perjury
suborning perjury and should be produced; Francisco Ramirez Cuellar, Esq.'s
remainder should be redacted as work monthly wire transfer for retainer
product; document provided to the Special fee incurred in pursuing litigation
Master contains redactions for non- against Drummond.
responsiveness

& Scherer's expenses incurred to
wire payments to Ivan Otero are closely Janette Perez,
Drummond, including information
Witness Bribery; Suborning related to or in furtherance of the alleged Terrence Catherine
287 CSPRIV401310 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 04/24/2012 Maggie Crosby reflecting Francisco Ramirez
Perjury crimes of witness bribery and suborning Collingsworth Salomon, Ty
Cuellar, Esq.'s monthly wire
perjury and should be produced; Allmandinger
transfer for retainer fee incurred in
Drummond.
responsiveness

discussing or reflecting wire payments Redacted email reflecting Conrad
made for Colombian witnesses and & Scherer's expenses incurred to
monthly wire payments to Ivan Otero are pursue litigation against
Janette Perez,
288 CSPRIV401314 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 04/24/2012 Maggie Crosby reflecting Francisco Ramirez
Perjury Collingsworth Salomon, Ty
Allmandinger
responsiveness
Chart of C&S expenses; entry reflecting
large payment to Ivan Otero for logistical Redacted document reflecting
and security costs is closely related to or in Terrence Collingsworth, Esq.'s
292 CSPRIV401338 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 1-65; 05/01/2012 C&S Accounting C&S Accounting reimbursement request for
Perjury
witness bribery and suborning perjury and expenses incurred to pursue
should be produced; remainder should be litigation against Drummond.
made for Colombian witnesses and Redacted email reflecting Conrad
monthly wire payments to Ivan Otero are & Scherer's expenses incurred to
closely related to or in furtherance of the pursue litigation against
298 CSPRIV401363 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 05/23/2012 Janette Perez Luisa Pavolini Drummond, including
Perjury
suborning perjury and should be produced; reimbursement request for work
remainder should be redacted as work performed by Conrad & Scherer's
product; document provided to the Special employees.
responsiveness

wire payments to Ivan Otero are closely
Witness Bribery; Suborning related to or in furtherance of the alleged
299 CSPRIV401367 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 05/23/2012 Janette Perez Luisa Pavolini Drummond, including
Perjury crimes of witness bribery and suborning
reimbursement request for work
perjury and should be produced;
performed by Conrad & Scherer's
employees.
responsiveness

made for Colombian witnesses and Redacted email reflecting Conrad
monthly wire payments to Ivan Otero are & Scherer's expenses incurred to
closely related to or in furtherance of the pursue litigation against
300 CSPRIV401371 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 05/23/2012 Janette Perez Luisa Pavolini Drummond, including
Perjury
suborning perjury and should be produced; reimbursement request for work
remainder should be redacted as work performed by Conrad & Scherer's
product; document provided to the Special employees.
responsiveness
made for Colombian witnesses and Documents and redacted email
monthly wire payments to Ivan Otero are reflecting Maria Gloria Rivas's
closely related to or in furtherance of the expenses incurred to pursue
304 CSPRIV401380 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 06/01/2012 C&S Accounting C&S Accounting litigation against Drummond,
Perjury
suborning perjury and should be produced; including reimbursement request
remainder should be redacted as work for work performed by Conrad &
product; document provided to the Special Scherer's employees.
responsiveness
Witness Bribery; Suborning 1-64; 1-65; 1- Drummond, including
305 CSPRIV401386 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 06/01/2012 C&S Accounting C&S Accounting
Perjury 71; reimbursement requests
containing privileged time entries
for work performed by Conrad &
Scherer's employees.
responsiveness
Documents reflecting Terrence
Chart of C&S expenses with receipts; entry
Collingsworth, Esq.'s
and receipt reflecting secuirty and logistics
reimbursement request for
payment to Ivan Otero in connection with
expenses incurred to pursue
Witness Bribery; Suborning witness testimony are closely related to or
312 CSPRIV401411 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 06/08/2012 C&S Accounting C&S Accounting litigation against Drummond,
Perjury in furtherance of the alleged crimes of
including notes and descriptions
witness bribery and suborning perjury and
related to strategy and mental
should be produced; the remainder should
impressions in anticipation of
be redacted
Bates
Number Redacted
applicable) Log?
Form
Catherine pursue litigation against
Witness Bribery; Suborning Terrence Salomon, Drummond, including information
324 CSPRIV401493 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 06/19/2012 Maggie Crosby
Perjury Collingsworth Janette Perez, reflecting work performed by
Ty Allmandinger Conrad & Scherer employees in
Drummond.
responsiveness

made for Colombian witnesses (or to Redacted email reflecting Conrad
Colombian intermediary) and monthly & Scherer's expenses incurred to
wire payments to Ivan Otero are closely Catherine pursue litigation against
Witness Bribery; Suborning related to or in furtherance of the alleged Terrence Salomon, Drummond, including information
325 CSPRIV401496 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 06/19/2012 Maggie Crosby
Perjury crimes of witness bribery and suborning Collingsworth Janette Perez, reflecting work performed by
perjury and should be produced; Ty Allmandinger Conrad & Scherer employees in
remainder should be redacted as work pursuing litigation against
product; document provided to the Special Drummond.
responsiveness

payments to Ivan Otero are closely related
to or in furtherance of the alleged crimes
Witness Bribery; Suborning Drummond, including information
332 CSPRIV401514 AWP Withheld Crime-Fraud Exception of witness bribery and suborning perjury 1-64; 1-65; 07/19/2012 C&S Accounting C&S Accounting
Perjury reflecting work performed by
Conrad & Scherer employees in
be redacted as work product; document
Drummond.

Redacted document reflecting
reimbursement request related to
wire payments to Ivan Otero are closely
work performed by Conrad &
Witness Bribery; Suborning related to or in furtherance of the alleged
341 CSPRIV401602 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 07/24/2012 C&S Accounting C&S Accounting Scherer employees and expenses
Perjury crimes of witness bribery and suborning
incurred by Conrad & Scherer to
Drummond.
responsiveness

monthly wire payments to Ivan Otero are Redacted documents reflecting
closely related to or in furtherance of the Gilma Yineth Baeza Acosta's
342 CSPRIV401605 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; 1-65; 08/03/2012 C&S Accounting C&S Accounting reimbursement request for
Perjury
suborning perjury and should be produced; expenses incurred to pursue
responsiveness
Witness Bribery; Suborning reimbursement request related to
Perjury work performed by Conrad &
Scherer employees.
responsiveness
Internal C&S communication discussing or

reflecting wire payments made for
Colombian witnesses (or to Colombian
intermediary) and monthly wire payments
information related to Conrad &
Witness Bribery; Suborning to Ivan Otero are closely related to or in
362 CSPRIV401706 AWP Withheld Crime-Fraud Exception 1-64; 1-65; 09/25/2012 C&S Accounting C&S Accounting Scherer's expenses incurred in
Perjury furtherance of the alleged crimes of
Drummond.
should be produced; document provided
to the Special Master contains redactions
for non-responsiveness
Internal C&S communication discussing or

reflecting wire payments made for
Colombian witnesses and monthly wire Redacted document reflecting
payments to Ivan Otero are closely related information related to Conrad &
363 CSPRIV401709 AWP Withheld Crime-Fraud Exception to or in furtherance of the alleged crimes 1-64; 1-65; 09/25/2012 C&S Accounting C&S Accounting Scherer's expenses incurred in
Perjury
of witness bribery and suborning perjury pursuing litigation against
and should be produced; document Drummond.
Ledger of C&S expenses reflecting
payments for Colombian witness and Redacted documents reflecting
monthly payments for Ivan Otero; closely Conrad & Scherer's expenses
related to or in furtherance of the alleged incurred to pursue litigation
440 CSPRIV402034 AWP Withheld Crime-Fraud Exception crimes of witness bribery and suborning 1-64; 1-65; 05/30/2013 C&S Accounting C&S Accounting against Drummond and Ivan Otero
Perjury
perjury and should be produced; Esq.'s reimbursement request for
document provided to the Special Master expenses incurred to pursue
contains redactions for non- unrelated litigation.
responsiveness
wire payment made for Colombian
witness and monthly wire payment to Ivan Redacted documents reflecting
Otero are closely related to or in Conrad & Scherer's expenses
furtherance of the alleged crimes of incurred in pursuing litigation
446 CSPRIV402053 AWP Withheld Crime-Fraud Exception witness bribery and suborning perjury and 1-64; 1-65; 06/19/2013 C&S Accounting C&S Accounting against Drummond, noting work
Perjury
should be produced; remaining portions performed by potential expert and
should be redacted as work product; expenses incurred by Ivan Otero
document provided to the Special Master Esq. to pursue unrelated litigation.
contains redactions for non-
responsiveness
Bates
Number Redacted
applicable) Log?
Form
Ledger of C&S expenses reflecting security

payments for Colombian witness and
monthly wire payments for Ivan Otero;
Witness Bribery; Suborning Conrad & Scherer's expenses
Perjury incurred in pursuing litigation
against Drummond.
document provided to the Special Master
responsiveness
witness and monthly wire payment to Ivan
Otero are closely related to or in Documents reflecting Gilma Yineth
furtherance of the alleged crimes of Baeza Acosta's reimbursement
466 CSPRIV402116 AWP Withheld Crime-Fraud Exception witness bribery and suborning perjury and 1-64; 1-65; 11/01/2013 C&S Accounting C&S Accounting request for expenses incurred to
Perjury
should be produced; remaining portions pursue litigation against
should be redacted as work product; Drummond.
responsiveness
witness and monthly wire payment to Ivan
Otero are closely related to or in Redacted documents reflecting
furtherance of the alleged crimes of Ivan Otero Esq.'s reimbursement
467 CSPRIV402122 AWP Withheld Crime-Fraud Exception witness bribery and suborning perjury and 1-64; 1-65; 11/01/2013 C&S Accounting C&S Accounting request for expenses incurred to
Perjury
should be produced; remaining portions pursue litigation against
should be redacted as work product; Drummond.
responsiveness
Bank statement/ledger of C&S expenses;
Internal law firm Accounting
entries reflecting monthly payments to
records reflecting bank statements
Ivan Otero are closely related to or in
Witness Bribery; Suborning that show Conrad & Scherer's
530 CSPRIV402705 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 1-65; Various dates C&S Accounting C&S Accounting
Perjury payments of its expenses incurred
in pursuing litigation against
Drummond.
Bank statement/ledger of C&S expenses;
Internal law firm Accounting
entries reflecting monthly payments to
records reflecting bank statements
Ivan Otero are closely related to or in
Witness Bribery; Suborning 2/1/2012- that show Conrad & Scherer's
531 CSPRIV402719 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 1-65; C&S Accounting C&S Accounting
Perjury 2/29/2012 payments of its expenses incurred
Drummond.
Email communication between

Collingsworth and Albert Van Bilderbeek;
Email from client to counsel
portion referencing moving family of
regarding case strategy and fact
Witness Bribery; Suborning Colombian witness is closely related to or 1-43; 1-44; 1- Albert
562 CSPRIV403016 ACC, AWP Withheld Crime-Fraud Exception 09/15/2010 Collingsworth gathering, witness to testify, bank
Perjury in furtherance of the alleged crimes of 64; 1-65; VanBilderbeek
funding, and other follow-up tasks
related to legal representation.
be redacted as attorney-client privileged
Email chain from Terrence

Collingsworth, Esq. to Mark
Carlson and Joseph Carrera related
to invoices for investigative and
Email correspondence among
security work performed at the
Collingsworth’s legal team and Secure
direction of counsel in anticipation
Point; portions discussing case funding and
of litigation and protected from
invoices in connection with testimony of
Witness Bribery; Suborning 3-9; 1-64; 4- Collingsworth, disclosure because it is privileged,
724 CSPRIV403533 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 07/03/2012 Carlson, Mark Carrera, Joseph CSPRIV403533
Perjury 5; Terrence subject to a Confidentiality
or in furtherance of the alleged crimes of
Agreement in the engagement
agreement between Conrad &
Scherer and Secure Pointe, and
subject to a Protective Order in
arbitration proceedings between
Conrad & Scherer and Secure
Pointe.
Email from Mark Carlson to
Terrence Collingsworth, Esq. and
Joseph Carrera related to invoices
Email communications among for investigative and security work
Collingsworth’s legal team and Secure performed at the direction of
Pointe; portions discussing Secure Point’s counsel in anticipation of litigation
funding and role with respect to obtaining Collingsworth, and protected from disclosure
Witness Bribery; Suborning 3-9; 4-5; 1- Collingsworth,
731 CSPRIV403547 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 08/09/2012 Carlson, Mark Terrence; because it is privileged, subject to CSPRIV403547
Perjury 64; Terrence
in furtherance of the alleged crimes of Carrera, Joseph a Confidentiality Agreement in the
witness bribery and suborning perjury and engagement agreement between
should be produced; the remainder should Conrad & Scherer and Secure
be redacted as work product Pointe, and subject to a Protective
Order in arbitration proceedings
between Conrad & Scherer and
Secure Pointe.
Email from Mark Carlson to

Terrence Collingsworth, Esq. and
Joseph Carrera related to invoices
Email communications among for investigative and security work
Collingsworth’s legal team and Secure performed at the direction of
Pointe; portions discussing Secure Point’s counsel in anticipation of litigation
funding and role with respect to obtaining Collingsworth, and protected from disclosure
Witness Bribery; Suborning 3-9; 4-5; 1- Collingsworth,
732 CSPRIV403551 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 08/09/2012 Carlson, Mark Terrence; because it is privileged, subject to CSPRIV403551
Perjury 64; Terrence
in furtherance of the alleged crimes of Carrera, Joseph a Confidentiality Agreement in the
witness bribery and suborning perjury and engagement agreement between
should be produced; the remainder should Conrad & Scherer and Secure
be redacted as work product Pointe, and subject to a Protective
Secure Pointe.
Bates
Number Redacted
applicable) Log?
Form
Email from T. Collingsworth, Esq.
to R. Drath and W. Scherer, Esq.
related to investigation activities
Email communication among
and security strategy for
Collingsworth's legal team; portion
underlying cases against
pertaining to request by Colombian
Drummond undertaken at the
witness for assistance with moving family
direction of counsel in anticipation
is closely related to or in furtherance of
Drath, Richard; of litigation and protected from
Witness Bribery; Suborning the alleged crimes of witness bribery and Collingsworth,
867 CSPRIV403900 AWP Withheld Crime-Fraud Exception 3-9; 4-5; 04/15/2011 Drath, Richard Scherer, William disclosure because it is privileged, CSPRIV403900
Perjury suborning perjury and should be produced; Terry
R subject to a Confidentiality
the remainder should be redacted.
Agreement in the engagement
Further, the version of the document
agreement between Conrad &
Scherer and Secure Pointe, and
redactions and cannot be reviewed in its
subject to a Protective Order in
entirety in its current form.
arbitration proceedings between
Pointe.
Email from Terrence Collingsworth,

Esq. to Lorraine Leete, Esq., Eric
Hager, Esq., Christian Levesque,
Susana Tellez and David F. Garces,
containing privileged discussions
Email communication among regarding legal strategy and
Collingsworth's legal team; portions containing counsel's mental
pertaining to request by Colombian impressions and related to
witness for payment of legal fees and Leete, Lorraine; investigation activities and security
portions pertaining to payments to Hager, Eric; strategy for underlying cases
Witness Bribery; Suborning Colombian witnesses, family of Colombian Collingsworth, Levesque, Collingsworth, against Drummond undertaken at CS_TC00528
1004 CSPRIV404525 AWP Withheld Crime-Fraud Exception 3-9; 4-5; 05/22/2011 CSPRIV404525
Perjury witnesses, and Ivan Otero for security are Terrence Christian; Terrence the direction of counsel in 9
closely related to or in furtherance of the Tellez, Susana; anticipation of litigation and
alleged crimes of witness bribery and Garces, David F protected from disclosure because
suborning perjury and should be produced; it is privileged, subject to a
the remainder should be redacted as work Confidentiality Agreement in the
product engagement agreement between
Pointe, and subject to a Protective
Secure Pointe.
Email between Collingsworth and Alber Va

Bilderbeek; portion reflecting possibiltiy of
providing security to family of Colombian Email from Albert Van Bilderbeek
Witness Bribery; Suborning witness is closely related to or in Van Bilderbeek, Collingsworth, to Terrence Collingsworth
2667 CSPRIV410940 ACC, AWP Withheld Crime-Fraud Exception 1-43; 1-44; 09/15/2010 CSPRIV410940
Perjury furtherance of the alleged crimes of Albert Terry regarding case preparation,
witness bribery and suborning perjury and strategy, and expenditures..

Collingsworth's legal team and consultant
who was paid $100,000; pursuant to the
Court's crime-fraud order (Doc. 417), the
second prong of the crime-fraud exception
E-mail from Terrence
Witness Bribery; Suborning has been satisfied with regard to this Collingsworth, VanBilderbeek,
2685 CSPRIV411019 ACC, AWP Withheld Crime-Fraud Exception 1-43; 1-44; 04/17/2012 Lassere, Andre Collingsworth to Lasserre Andre CSPRIV411019
Perjury consultant, his identity, the work Terry Albert
regarding case strategy.
performed, and payments made; this
email exchange pertains to his identity and
the work performed, is closely related to
witness bribery and suborning perjury, and
should be produced
C&S attorney timesheet; version provided

for non-responsiveness; entries pertaining
to wires/payments to Ivan Otero for
security, to Colombian witnesses, and to
Witness Bribery; Suborning Timesheet reflecting case
2809 CSPRIV411868 AWP Withheld Crime-Fraud Exception families of Colombian witnesses are 1-75; 12/10/2013 Susana Tellez CSPRIV411868
Perjury expenditures.
alleged crimes of witness bribery and
the remainder should be redacted as work
product

product

product

product
Bates
Number Redacted
applicable) Log?
Form

to payment of Colombian witness's legal
2851 CSPRIV412811 AWP Withheld Crime-Fraud Exception fees are closely related to or in 1-64; Scherer, William CSPRIV412811
furtherance of the alleged crimes of
be redacted as work product
C&S attorney timesheet; entries reflecting

security payments for Colombian
witnesses are closely related to or in
Witness Bribery; Suborning Leete, Lorraine; Timesheet reflecting case
2852 CSPRIV412903 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 04/01/2011 CSPRIV412903
Perjury Esty, Aaron expenditures and case preparation.
Etsy, Aaron;
Leete, Lorraine;
communications with Ivan Otero regarding
Parker, Brian;
security are closely related to or in
Witness Bribery; Suborning Beckington, Timesheet reflecting case
2854 CSPRIV412925 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 12/01/2011 CSPRIV412925
Perjury Andrew; expenditures and case preparation.
Ryerson,
Charity; Perillo,
Bob
Chart of C&S expenses; entries reflecting

payments to Colombian witnesses or
family members of Colombian witnesses
are closely related to or in furtherance of
Witness Bribery; Suborning the alleged crimes of witness bribery and Spreadsheet reflecting case
2984 CSPRIV413521 AWP Withheld Crime-Fraud Exception 1-64; 06/30/2011 CSPRIV413521
Perjury suborning perjury and should be produced; expenditures.
product; note: document already contains
numerous redactions reflecting "non-
responsive" material
Chart of expenses; entries reflecting

payments to Colombian witnesses, family
members of Colombian witnesses,
Colombian intermediary, and Ivan Otero
Witness Bribery; Suborning for security are closely related to or in Spreadsheet reflecting case
Perjury furtherance of the alleged crimes of expenditures.
redacted as work product; note: document
already contains numerous redactions
Chart of PWA expenses; entries related to

security payments are closely related to or
in furtherance of the alleged crimes of
Witness Bribery; Suborning Spreadsheet reflecting case
2986 CSPRIV413547 AWP Withheld Crime-Fraud Exception witness bribery and suborning perjury and 1-64; 12/01/2010 CSPRIV413547
redacted as work product; note: document
already contains numerous redactions

payments to Colombian witnesses, to
family members of Colombian witnesses,
to Colombian intermediary who facilitated
payments to Colombian witnesses, and to
Witness Bribery; Suborning Attachment reflecting case CS_TC00146
3039 CSPRIV413719 AWP Withheld Crime-Fraud Exception Ivan Otero for monthly or security 4-5; 1-65; CSPRIV413718
Perjury expenditures. 9
payments are closely related to or in
should be produced; the remaining entries
should be redacted as work product



Witness Bribery; Suborning Document reflecting case CS_TC00161
Bates
Number Redacted
applicable) Log?
Form

Witness Bribery; Suborning Attachment reflecting case
Summary chart of C&S expenditures;

entries reflecting payments to Colombian
witnesses, to family members of
Colombian witnesses, to intermediatry
who facilitated payments to Colombian
3056 CSPRIV413978 AWP Withheld Crime-Fraud Exception witnesses, and to Ivan Otero for witness 4-5; 1-64; CSPRIV413977
or security payments are closely related to
redacted

redacted

redacted

witnesses, to intermediatry who
facilitated payments to Colombian
Witness Bribery; Suborning witnesses, and to Ivan Otero for witness Attachment reflecting case
3065 CSPRIV414118 AWP Withheld Crime-Fraud Exception 4-5; 1-64; CSPRIV414117
Perjury or security payments are closely related to expenditures.
redacted

witnesses and to intermediatry who
facilitated payments to Colombian
3067 CSPRIV414172 AWP Withheld Crime-Fraud Exception witnesses are closely related to or in 4-5; 1-64; CSPRIV414171
redacted
C&S monthly payments; entries reflecting
payments for Colombian witnesses are
3072 CSPRIV414221 AWP Withheld Crime-Fraud Exception alleged crimes of witness bribery and 1-64; CSPRIV414220
product

Receipt or document evidencing payment

from C&S to Colombian witness and/or to
Colombian intermediary who facilitated Document reflecting Conrad &
Witness Bribery; Suborning payments to witnesses is closely related to Scherer’s expenses incurred in CS_TC00033
3890 CSPRIV436162 AWP Withheld Crime-Fraud Exception 1-64; 10/28/2009 C&S Accounting
Perjury or in furtherance of the alleged crimes of pursuing litigation against 7
witness bribery and suborning perjury and Drummond.
should be produced; remaining portions
Receipt or document evidencing payment

from C&S to Colombian intermediary who
facilitated payments to witnesses is Document reflecting Conrad &
Witness Bribery; Suborning closely related to or in furtherance of the Scherer’s expenses incurred in CS_TC00034
Perjury alleged crimes of witness bribery and pursuing litigation against 0
suborning perjury and should be produced; Drummond.
remaining portions should be redacted as
work product
Confirmation of payment from C&S to
Colombian intermediary who facilitated
Document reflecting Conrad &
payments to witnesses is closely related to
Witness Bribery; Suborning Scherer’s expenses incurred in CS_TC00035
3904 CSPRIV436213 AWP Withheld Crime-Fraud Exception or in furtherance of the alleged crimes of 1-64; 02/04/2010 C&S Accounting
Perjury pursuing litigation against 4
Drummond.
Bates
Number Redacted
applicable) Log?
Form

Drummond.
Drummond.
Drummond.
Drummond.
Drummond.
Internal C&S email communication;
portions discussing or reflecting payments
to Colombian witnesses and to Ivan Otero Document reflecting Conrad &
Witness Bribery; Suborning for security are closely related to or in Scherer’s expenses incurred in CS_TC00040
Perjury furtherance of the alleged crimes of pursuing litigation against 9
portions discussing or reflecting payments
to Colombian witnesses and to Ivan Otero Document reflecting Conrad &
Witness Bribery; Suborning for security are closely related to or in Scherer’s expenses incurred in CS_TC00041
3930 CSPRIV436302 AWP Withheld Crime-Fraud Exception 1-64; 02/21/2012 T. Collingsworth M. Crosby
Chart of C&S expenses; entry reflecting
payment to Ivan Otero for logistical and Email from Terrrence
security costs is closely related to or in Collingsworth to Maggie Crosby
3934 CSPRIV436313 AWP Withheld Crime-Fraud Exception furtherance of the alleged crimes of 1-64; 05/01/2012 C&S Accounting reflecting Conrad & Scherer’s
Perjury
witness bribery and suborning perjury and expenses incurred in pursuing
should be produced; remaining portions litigation against Drummond.
Various receipts for reimbursement;
receipt reflecting payment to Ivan Otero
for logistical and security issues is closely Document reflecting Conrad &
Witness Bribery; Suborning related to or in furtherance of the alleged Scherer’s expenses incurred in CS_TC00041
Perjury crimes of witness bribery and suborning pursuing litigation against 5
perjury and should be produced; Drummond.
work product
List of C&S expenses; entries reflecting
wire payments to Ivan Otero for work in
cases and to co-counsel for Colombian Document reflecting Conrad &
Witness Bribery; Suborning witness are closely related to or in Scherer’s expenses incurred in CS_TC00042
List of C&S expenses; entries reflecting
wire payments to Ivan Otero for work in
cases (and internal emails reflecting the
same) and to co-counsel for Colombian
3943 CSPRIV436350 AWP Withheld Crime-Fraud Exception witness are closely related to or in 1-64; 11/27/2012 C&S Accounting
Drummond.
Drummond.
payments to witnesses and internal C&S
email reflecting the same are closely
3967 CSPRIV436486 AWP Withheld Crime-Fraud Exception related to or in furtherance of the alleged 1-64; 02/20/2009 C&S Accounting
crimes of witness bribery and suborning
Drummond.
product
Internal C&S communication reflecting
Email chain from Mindy Drath to
and discussing wire payment used for
Janette Perez reflecting Conrad &
Witness Bribery; Suborning security/relocation of Colombian witness;
3968 CSPRIV436493 AWP Withheld Crime-Fraud Exception 1-64; 02/26/2009 C&S Accounting Scherer’s expenses incurred in
Perjury closely related to or in furtherance of
Drummond.
suborning perjury and should be produced
Bates
Number Redacted
applicable) Log?
Form
Internal C&S communication discussing,

and payment records reflecting, wire
payment used for security/relocation of
Witness Bribery; Suborning Scherer’s expenses incurred in
3979 CSPRIV436573 AWP Withheld Crime-Fraud Exception Colombian witness; closely related to or in 1-64; 04/30/2009 C&S Accounting
Perjury pursuing litigation against
furtherance of alleged crimes of witness
Drummond.
bribery and suborning perjury and should
be produced
Chart of C&S expenses or payments;

entries related to payments to Colombian
witnesses, to Colombian intermediary who
facilitated payments to witnesses, to
4009 CSPRIV436859 AWP Withheld Crime-Fraud Exception and to Ivan Otero in large amounts are 1-64; C&S Accounting
Drummond.
product

witnesses and to Colombian intermediary
who facilitated payments to witnesses are
4011 CSPRIV436898 AWP Withheld Crime-Fraud Exception closely related to or in furtherance of the 1-64; C&S Accounting
Drummond.
product

witnesses, to Colombian intermediary who
facilitated payments to witnesses, to
4013 CSPRIV436958 AWP Withheld Crime-Fraud Exception and to Ivan Otero in large amounts are 1-64; C&S Accounting
Drummond.
product

security payments for Colombian
witnesses and to Ivan Otero and payment
of Colombian witness's legal fees are
Witness Bribery; Suborning Document reflecting case
4014 CSPRIV437039 AWP Withheld Crime-Fraud Exception closely related to or in furtherance of the 1-64; C&S Accounting
Perjury expenditures
product
portions pertaining to monthly wires to
Redacted email chain between M.
Colombian witnesses and to Ivan Otero for
Crosby, T. Allamandinger, and T.
Witness Bribery; Suborning security are closely related to or in Allmandinger, CS_TC00058
4017 CSPRIV437314 AWP Withheld Crime-Fraud Exception 1-64; 01/06/2012 Crosby, Maggie Collingsworth related to related to CSPRIV437314
Perjury furtherance of the alleged crimes of Ty 5
request for reimbursement and
reflecting case expenditures.
portions pertaining to monthly wires to
Redacted email chain between M.
Colombian witnesses and to Ivan Otero for
Crosby and T. Collingsworth, Esq.
Witness Bribery; Suborning security are closely related to or in Collingsworth, CS_TC00058
4018 CSPRIV437316 AWP Withheld Crime-Fraud Exception 1-64; 01/03/2012 Crosby, Maggie related to request for CSPRIV437316
Perjury furtherance of the alleged crimes of Terrence 7
reimbursement and reflecting case
expenditures.
Redacted email with attachments

from M. Crosby to C. Salomon and
Internal C&S email communication; T. Allmandinger related to
portions pertaining to monthly wires for reimbursement requests and
Salomon,
Colombian witnesses are closely related to reflecting case expenditures for
Witness Bribery; Suborning Catherine; CS_TC00059
4021 CSPRIV437322 AWP Withheld Crime-Fraud Exception or in furtherance of the alleged crimes of 1-64; 01/17/2012 Crosby, Maggie expenses incurred by Conrad & CSPRIV437322
Perjury Allmandinger, 3
witness bribery and suborning perjury and Scherer in pursuing litigation
Ty
should be produced; remainder should be against Drummond, including time
redacted as work product entries and receipts relating to
expenses incurred in pursuing

portions pertaining to monthly wires for
Email chain involving T.
Colombian witnesses, to Colombian
Collingsworth, Esq., T. Allmandiger,
intermediary who facilitated payments to
Allmandinger, and C. Salomon related to
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Collingsworth, CS_TC00060
4024 CSPRIV437336 AWP Withheld Crime-Fraud Exception 1-64; 01/25/2012 Ty; Salomon, Crosby, Maggie reimbursement requests and case CSPRIV437336
Perjury are closely related to or in furtherance of Terrence 7
Catherine expenditures for expenses incurred
the alleged crimes of witness bribery and
Drummond.
product
Email from M. Crosby to T.
Collingsworth, Esq. related to
intermediary who facilitated payments to Perez, Janette;
requests for reimbursement and
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Collingsworth, Allmandinger, CS_TC00060
4027 CSPRIV437340 AWP Withheld Crime-Fraud Exception 1-64; 03/20/2012 Crosby, Maggie reflecting case expenditures, CSPRIV437340
Perjury are closely related to or in furtherance of Terrence Ty; Salomon, 9
including time entries for work
the alleged crimes of witness bribery and Catherine
performed in underlying
Drummond litigation.
product
Email chain from T. Collingsworth,
Esq. to M. Crosby related to
intermediary who facilitated payments to Allmandinger,
requests for reimbursements and
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Collingsworth, Ty; Catherine, CS_TC00062
4028 CSPRIV437352 AWP Withheld Crime-Fraud Exception 1-64; 03/20/2012 Crosby, Maggie reflecting case expenditures, CSPRIV437352
Perjury are closely related to or in furtherance of Terrence Catherine; 1
including time entries for work
the alleged crimes of witness bribery and Perez, Janette
performed in litigation against
Drummond.
product
Bates
Number Redacted
applicable) Log?
Form
Email chain from Catherine
Salomon to Janette Perez related
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Salomon, CS_TC00062
4029 CSPRIV437354 AWP Withheld Crime-Fraud Exception 1-64; 03/30/2012 Perez, Janette to reimbursement requests and CSPRIV437354
Perjury are closely related to or in furtherance of Catherine 3
reflecting case expenditures,
including time entries.
product
Colombian witnesses, to Colombian Email from M. Crosby to T.
intermediary who facilitated payments to Perez, Janette; Collingsworth, Esq. related to
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Collingsworth, Salomon, reimbursement requests and CS_TC00065
4030 CSPRIV437384 AWP Withheld Crime-Fraud Exception 1-64; 1-74; 04/24/2012 Crosby, Maggie CSPRIV437384
Perjury are closely related to or in furtherance of Terrence Catherine; reflecting case expenditures for 3
the alleged crimes of witness bribery and Allmandinger, Ty expenses incurred in pursuing
suborning perjury and should be produced; litigation against Drummond.
product
intermediary who facilitated payments to Redacted email chain involving C.
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Salomon, Salomon to R. Drath related to CS_TC00070
4031 CSPRIV437439 AWP Withheld Crime-Fraud Exception 1-64; 04/30/2012 Drath, Richard CSPRIV437439
Perjury are closely related to or in furtherance of Catherine reimbursement requests and 8
the alleged crimes of witness bribery and reflecting case expenditures.
product
Colombian witnesses, to Colombian Email chain from J. Perez, L.
intermediary who facilitated payments to Pavolini, and M. Crosby related to
Witness Bribery; Suborning witnesses, and to Ivan Otero for security reimbursement requests and CS_TC00071
4032 CSPRIV437443 AWP Withheld Crime-Fraud Exception 1-64; 05/04/2012 Perez, Janette Pavolini, Luisa CSPRIV437443
Perjury are closely related to or in furtherance of reflecting case expenditures, 2
the alleged crimes of witness bribery and including time entries for work
suborning perjury and should be produced; performed on the case.
product
Email chain from J. Perez and M.
Crosby related to reimbursement
requests and reflecting case
Witness Bribery; Suborning witnesses, and to Ivan Otero for security CS_TC00076
4033 CSPRIV437499 AWP Withheld Crime-Fraud Exception 1-64; 05/30/2012 Perez, Janette Crosby, Maggie Pavolini, Luisa expenditures, including time CSPRIV437499
Perjury are closely related to or in furtherance of 8
entries for work performed in
Drummond.
product
intermediary who facilitated payments to Redacted email chain from M.
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Crosby to J. Perez related to CS_TC00078
4034 CSPRIV437517 AWP Withheld Crime-Fraud Exception 1-64; 05/30/2012 Crosby, Maggie Perez, Janette CSPRIV437517
Perjury are closely related to or in furtherance of reimbursement requests and 6
the alleged crimes of witness bribery and reflecting case expenditures.
product
Colombian witnesses, to Colombian Redacted email chain from M.
intermediary who facilitated payments to Crosby,to J. Perez related to
Witness Bribery; Suborning witnesses, and to Ivan Otero for security reimbursement requests and CS_TC00079
4035 CSPRIV437521 AWP Withheld Crime-Fraud Exception 1-64; 05/30/2012 Crosby, Maggie Perez, Janette CSPRIV437521
Perjury are closely related to or in furtherance of reflecting case expenditures for 0
the alleged crimes of witness bribery and expenses incurred in pursuing
suborning perjury and should be produced; litigation against Drummond.
product
Colombian witnesses, to Colombian Email from M. Crosby to T.
intermediary who facilitated payments to Salomon, Collingsworth, Esq. related to
Witness Bribery; Suborning witnesses, and to Ivan Otero for security Collingsworth, Catherine; reimbursement requests and CS_TC00079
4036 CSPRIV437525 AWP Withheld Crime-Fraud Exception 1-64; 06/19/2012 Crosby, Maggie CSPRIV437525
Perjury are closely related to or in furtherance of Terrence Perez, Janette; reflecting time entries, including 4
the alleged crimes of witness bribery and Allmandinger, Ty time entries for work performed in
suborning perjury and should be produced; underlying Drummond litigation.
product
Colombian witnesses, to Colombian Email chain from M. Crosby to L.
intermediary who facilitated payments to Pavolini related to reimbursement
Salomon,
Witness Bribery; Suborning witnesses, and to Ivan Otero for security requests and reflecting case CS_TC00082
4039 CSPRIV437561 AWP Withheld Crime-Fraud Exception 1-64; 06/26/2012 Crosby, Maggie Pavolini, Luisa Catherine; CSPRIV437561
Perjury are closely related to or in furtherance of expenditures for expenses incurred 0
Perez, Janette
the alleged crimes of witness bribery and in pursuing litigation against
suborning perjury and should be produced; Drummond.
product
Colombian witnesses, to Colombian Email chain from M. Crosby, L.
intermediary who facilitated payments to Pavolini, to T. Collingsworth
Witness Bribery; Suborning witnesses, and to Ivan Otero for security related to reimbursement requests CS_TC00082
4040 CSPRIV437564 AWP Withheld Crime-Fraud Exception 1-64; 06/26/2012 Crosby, Maggie Pavolini, Luisa CSPRIV437564
Perjury are closely related to or in furtherance of and reflecting case expenditures 3
the alleged crimes of witness bribery and incurred in pursuing litigation
suborning perjury and should be produced; against Drummond.
product
"Richard Drath
Email communication among <rdrath11@yah
Collingsworth's legal team; portion "'Terrence oo.com>"
discussing funding of Colombian witness's Collingsworth' <rdrath11@yah
Lee Bialostok Email from L. Bialostok to T.
Witness Bribery; Suborning legal fees is closely related to or in <tc@iradvocate oo.com>; "Bill
4836 CSPRIV440255 AWP Withheld Crime-Fraud Exception 1-64; 06/06/2011 <lee@plattelaw Collingsworth regarding case CSPRIV440255
Perjury furtherance of the alleged crimes of s.org>" Scherer
.com> expenditures.
witness bribery and suborning perjury and <tc@iradvocate <wrs@conradsc
should be produced; remainder should be s.org> herer.com>"
redacted as work product <wrs@conradsc
herer com>
Bates
Number Redacted
applicable) Log?
Form

"Victoria D.
pertaining to wire payments to Colombian
Ryan
witnesses and to Ivan Otero for security
Witness Bribery; Suborning tc@iradvocates. <VRyan@conra Email from T. Collingsworth to V. CS_TC00547
4935 CSPRIV440507 AWP Withheld Crime-Fraud Exception are closely related to or in furtherance of 1-64; 07/26/2011 CSPRIV440507
Perjury org dscherer.com>" Ryan regarding case expenditures. 6
<VRyan@conra
dscherer.com>
product
"Terry
Collingsworth
<tc@iradvocate
s.org>"
<tc@iradvocate
s.org>;
"Catherine H.
Salomon
<csalomon@con
radscherer.com
Email communication among >"
Collingsworth's legal team; portion <csalomon@con
"Victoria D.
pertaining to wire payments to Colombian radscherer.com
Ryan
witnesses and to Ivan Otero for security >; "Janette Perez
Witness Bribery; Suborning tc@iradvocates. <VRyan@conra Email from T. Collingsworth to V. CS_TC00547
4936 CSPRIV440508 AWP Withheld Crime-Fraud Exception are closely related to or in furtherance of 1-64; 07/26/2011 <jperez@conrad CSPRIV440508
Perjury org dscherer.com>" Ryan regarding case expenditures. 7
the alleged crimes of witness bribery and scherer.com>"
<VRyan@conra
suborning perjury and should be produced; <jperez@conrad
dscherer.com>
remainder should be redacted as work scherer.com>;
product "Lorraine O.
Sarfati
<lsarfati@conra
dscherer.com>"
<lsarfati@conra
dscherer.com>;
"Susana Tellez
<stellez@conrad
scherer.com>"
<stellez@conrad
scherer.com>

pertaining to monthly wire payment to
Attachment reflecting case
Witness Bribery; Suborning Ivan Otero is closely related to or in Conrad & CS_TC00029
5170 CSPRIV441177 AWP Withheld Crime-Fraud Exception 1-64; 01/31/2012 expenditures. CSPRIV441177
Perjury furtherance of the alleged crimes of Scherer 1
Collingsworth's legal team; portions
pertaining to monthly wire payments for
Colombian witnesses and to Ivan Otero Attachment reflecting case
Witness Bribery; Suborning Conrad & CS_TC00029
5191 CSPRIV441255 AWP Withheld Crime-Fraud Exception are closely related to or in furtherance of 1-64; 07/10/2012 expenditures. CSPRIV441255
Perjury Scherer 6
product
Perjury Scherer 1
product
Perjury Scherer 4
product
Perjury Scherer 0
product
Pointe; portion pertaining to payment to
Mark Carlson
Secure Point in connection with meeting,
<mark.carlson@ Email from Terrence
deposition, and relationship with
sppi-llc.com>; Joseph Carrera Collingsworth, Esq. to Joseph
Witness Bribery; Suborning Colombian witness is closely related to or Terrence
5516 CSPRIV442025 AWP, CI Withheld Crime-Fraud Exception 4-5; 08/08/2012 Terry <joseph.carrera Carrera regarding privileged
Perjury in furtherance of the alleged crimes of Collingsworth
Collingsworth @sppi-llc.com> investigative work on behalf of
<Tc@conradsch Conrad & Scherer.
should be produced; the remaining
erer.com>
portions are not closely related to or in
furtherance of the alleged crimes and
E-mail correspondence among
Mark Carlson
Point; portion discussing payments to
<mark.carlson@ Email from Terrence
Secure Point for purposes of obtaining
sppi-llc.com>; Joseph Carrera Collingsworth, Esq. to Mark
Witness Bribery; Suborning specific testimony from Colombian Terrence
5517 CSPRIV442029 AWP, CI Withheld Crime-Fraud Exception 4-5; 10/04/2012 Terrence <joseph.carrera Carlson regarding privileged
Perjury witness are closely related to or in Collingsworth
Collingsworth @sppi-llc.com> investigative work on behalf of
<TC@conradsch Conrad & Scherer.
witness bribery and suborning perjury are
erer.com>
should be produced; remaining portion of
email should be redacted as work product
Bates
Number Redacted
applicable) Log?
Form
Mark Carlson
Point; portions discussing payments to
<mark.carlson@
Secure Point for purposes of obtaining Email from Terrence Collingsworth,
Joseph Carrera sppi-llc.com>;
Witness Bribery; Suborning specific testimony from Colombian Terrence Esq. to Joseph Carrera regarding
5518 CSPRIV442031 AWP, CI Withheld Crime-Fraud Exception 4-5; 10/04/2012 <joseph.carrera Terrence
Perjury witness are closely related to or in Collingsworth privileged investigative work on
@sppi-llc.com> Collingsworth
furtherance of the alleged crimes of behalf of Conrad & Scherer.
<TC@conradsch
erer.com>
Internal memorandum dated March 31,
2011; portions discussing funding for
security for Colombian witness, security
payments for families of Colombian
witnesses, and request by Colombian
Witness Bribery; Suborning Attorney working files reflecting
5689 CSPRIV442651 AWP, CI Withheld Crime-Fraud Exception witness for payment of legal fees are 4-5; 03/31/2011 CSPRIV442651
Perjury investigative work.
product
product
Internal memorandum dated Oct 19,
2011; portions discussing requests by
witnesses for security for family in
connection with signing declaration are
5692 CSPRIV442669 AWP, CI Withheld Crime-Fraud Exception closely related to or in furtherance of the 4-5; 10/24/2011 CSPRIV442669
product
product
Witness Bribery; Suborning Attorney notes reflecting
product
connection with signing declaration are
Witness Bribery; Suborning Attorney notes reflecting
5697 CSPRIV442704 AWP, CI Withheld Crime-Fraud Exception closely related to or in furtherance of the 4-5; 10/24/2011 CSPRIV442704
product

Point; portions discussing case funding and Email to Mark Carlson from
invoices in connection with testimony of Terrence Collingsworth reflecting
5797 CSPRIV442877 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 07/03/2012 T. Collingsworth M. Carlson J. Carrera investigative work and case CSPRIV442877
Perjury
or in furtherance of the alleged crimes of preparation on behalf of Conrad &
witness bribery and suborning perjury and Scherer.

Point; portions discussing case funding and Email to Mark Carlson from
invoices in connection with testimony of Terrence Collingsworth reflecting
5798 CSPRIV442879 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 07/03/2012 T. Collingsworth M. Carlson J. Carrera investigative work and case CSPRIV442879
Perjury
or in furtherance of the alleged crimes of preparation on behalf of Conrad &
Email communications among

Pointe; portions discussing Secure Point’s Email from Joseph Carrera to
funding and role with respect to obtaining Terrence Collingsworth reflecting
5805 CSPRIV442892 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 4-5; 08/09/2012 investigative work and case CSPRIV442892
Perjury
in furtherance of the alleged crimes of preparation on behalf of Conrad &
Pointe; portions discussing Secure Point’s Email from Joseph Carrera to
funding and role with respect to obtaining Terrence Collingsworth reflecting
5806 CSPRIV442896 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 4-5; 08/09/2012 M. Carlson T. Collingsworth T. Collingsworth investigative work and case CSPRIV442896
Perjury
in furtherance of the alleged crimes of preparation on behalf of Conrad &
Bates
Number Redacted
applicable) Log?
Form
Point; portions discussing payments to
Email from Joseph Carrera to
Secure Point for purposes of obtaining
Terrence Collingsworth reflecting
Witness Bribery; Suborning specific testimony from Colombian
5811 CSPRIV442905 AWP Withheld Crime-Fraud Exception 4-5; 10/04/2012 investigative work and case CSPRIV442905
Perjury witness are closely related to or in
preparation on behalf of Conrad &
Scherer.
Internal memorandum dated Feb 7, 2012;
portion discussing requests by witnesses
for security payment is closely related to Attachment reflecting investigative
5853 CSPRIV443317 AWP Withheld Crime-Fraud Exception or in furtherance of the alleged crimes of 4-5; 02/07/2012 work and case preparation on CSPRIV443317
Perjury
witness bribery and suborning perjury and behalf of Conrad & Scherer.
connection with signing declaration are Attachment reflecting investigative
5854 CSPRIV443326 AWP Withheld Crime-Fraud Exception closely related to or in furtherance of the 4-5; 10/19/2011 work and case preparation on CSPRIV443326
Perjury
alleged crimes of witness bribery and behalf of Conrad & Scherer.
product
Drummond-related Memo dated January

26–February 3; portions pertaining to
security funding requests by Colombian
witnesses and Ivan Otero, and terms for Attachment reflecting investigative
5855 CSPRIV443334 AWP Withheld Crime-Fraud Exception providing the funding, are closely related 4-5; 02/03/2012 work and case preparation on CSPRIV443334
Perjury
to or in furtherance of the alleged crimes behalf of Conrad & Scherer.
of witness bribery and suborning perjury

witnesses and Ivan Otero, and terms for Attachment reflecting investigative
Perjury

witnesses and Ivan Otero, and terms for Document reflecting investigative
Perjury
Email among Collingsworth's legal team

and co-counsel; portions discussing
request by Colombian witness for
payment of legal fees, and considerations
E-mail from Terrence
Witness Bribery; Suborning of implications regarding payment of Terrence R. Drath; W.
5984 CSPRIV451544 AWP Withheld Crime-Fraud Exception 4-5; 03/04/2011 R. Drath Collingsworth to Richard Drath CSPRIV451544
Perjury witness's legal fees are closely related to Collingsworth Scherer
regarding investigative work.

and co-counsel; portions discussing use of
funds in connection with Colombian
witness and portions discussing request by
Email from Terrence Collingsworth
Witness Bribery; Suborning Colombian witness for payment of legal Terry W. Scherer; T.
5988 CSPRIV451557 AWP Withheld Crime-Fraud Exception 4-5; 05/30/2011 L. Bialostok to Lee Biastolok and Richard Drath CSPRIV451557
Perjury fees are closely related to or in Collingsworth Collingsworth
regarding investigative work.
Email from William Scherer, III to
Witness Bribery; Suborning Colombian witness for payment of legal William R. R. Drath; W.
5989 CSPRIV451561 AWP Withheld Crime-Fraud Exception 4-5; 05/31/2011 Richard Drath regarding CSPRIV451561
Perjury fees are closely related to or in Scherer, III Scherer
investigative work.
witness and portions discussing request by Email from Pauline Koper to
Witness Bribery; Suborning Colombian witness for payment of legal William Scherer and Danielle
5990 CSPRIV451565 AWP Withheld Crime-Fraud Exception 4-5; 06/01/2011 Pauline Koper W. Scherer D. Kisslan CSPRIV451565
Perjury fees are closely related to or in Kisslan regarding investigative
furtherance of the alleged crimes of work.
and co-counsel; portion of email
M. Hugo; C.
discussing the need to address the request Email from Terrence Collingsworth
Levesque; E.
by Colombian witness for payment of legal J. Parker; L. to Mike Hugo, Christian Levesque,
Witness Bribery; Suborning Terry Hager; G.
5991 CSPRIV451567 AWP Withheld Crime-Fraud Exception fees is closely related to or in furtherance 4-5; 06/07/2011 Bialostok; F. Eric Hager, Gary Falkowitz, Peter CSPRIV451567
Perjury Collingsworth Falkowitz; P.
of the alleged crimes of witness bribery Rosenthal Cambs and WIlliams Scherer
Cambs; W.
and suborning perjury and should be regarding investigative work.
Scherer
produced; remainder should be redacted
as work product
Bates
Number Redacted
applicable) Log?
Form

has been satisfied with regard to this
P. Koper; R. Email from Terrence Collingsworth
Witness Bribery; Suborning consultant, his identity, the work Terrence
5993 CSPRIV451573 AWP Withheld Crime-Fraud Exception 4-5; 06/14/2011 W. Scherer Drath; T. to William Scherer regarding CSPRIV451573
Perjury performed, and payments made; this Collingsworth
Collingsworth investigative work.
the work performed (as well as discusses
request by Colombia witness for
assistance with legal fees), is closely
perjury, and should be produced
Collingsworth's legal team and co-counsel;
portions reflecting discussion about T. E-mail from Terrence
request by and/or payment of Colombian Collingsworth; Collingsworth to Richard
Witness Bribery; Suborning Terrence
5994 CSPRIV451577 AWP Withheld Crime-Fraud Exception witness's legal fees are closely related to 4-5; 06/15/2011 R. Drath; W. Drath,WIlliam R. Scherer and CSPRIV451577
Perjury Collingsworth
or in furtherance of the alleged crimes of Scherer; R. Pauline Koper regarding
witness bribery and suborning perjury; Koper investigative work.
work product

Point; portions discussing case funding and Email chain from Terrence
invoices in connection with testimony of Collingsworth to Mark Carlson
6106 CSPRIV451830 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 1-64; 07/03/2012 T. Collingsworth M. Carlson J. Carrera regarding privileged investigative CSPRIV451830
Perjury
or in furtherance of the alleged crimes of work on behalf of Conrad &

Point; portions discussing case funding and Email chain from Terrence
invoices in connection with testimony of Collingsworh to Mark Carlson
6107 CSPRIV451832 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 1-64; 07/03/2012 T. Collingsworth M. Carlson regarding privileged investigative CSPRIV451832
Perjury
or in furtherance of the alleged crimes of work on behalf of Conrad &

Pointe; portions discussing Secure Point’s Email from Mark Carlson to
funding and role with respect to obtaining Terrence Collingsworth and Joseph
6114 CSPRIV451845 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 4-5; 1-64; 08/09/2012 Carrera regarding privileged CSPRIV451845
Perjury
in furtherance of the alleged crimes of investigative work on behalf of
witness bribery and suborning perjury and Conrad & Scherer.
Pointe; portions discussing Secure Point’s Email from Mark Carlson to
funding and role with respect to obtaining Terrence Collingsworth and Joseph
6115 CSPRIV451849 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 4-5; 1-64; 08/09/2012 Carreraregarding privileged CSPRIV451849
Perjury
in furtherance of the alleged crimes of investigative work on behalf of
witness bribery and suborning perjury and Conrad & Scherer.
Pointe; portions discussing Secure Point’s
funding and role with respect to obtaining
Witness Bribery; Suborning to Joseph Carrera regarding
6125 CSPRIV452004 AWP Withheld Crime-Fraud Exception witness testimony are closely related to or 4-5; 1-64; 01/12/2012 CSPRIV452004
Perjury privileged investigative work on
behalf of Conrad & Scherer.
Lengthy compilation of emails and other
documents; the portions discussing
payment of legal fees and internal
discussions of whether to make such
Witness Bribery; Suborning witness bribery and suborningp perjury Terry
6154 CSPRIV452207 AWP Withheld Crime-Fraud Exception 4-5; 1-64; 06/08/2010 to Richard Drath regarding CSPRIV452207
Perjury and should be produced; portions Collingsworth
privileged investigative work.
discussing participation of witness after
family was moved are closely related to or
should be produced; the remaining
portions should be redacted as work
product

and co-counsel; portions discussing
payment of legal fees, and considerations
Witness Bribery; Suborning of implications regarding payment of Terrence
6247 CSPRIV453258 AWP Withheld Crime-Fraud Exception 4-5; 04/15/2011 Collingsworth to Richard Drath CSPRIV453258
Perjury witness's legal fees are closely related to Collingsworth

Collingsworth to Lee Bialostok and
Witness Bribery; Suborning Colombian witness for payment of legal Terry
6251 CSPRIV453271 AWP Withheld Crime-Fraud Exception 4-5; 05/30/2011 Richard Drath regarding CSPRIV453271
Perjury fees are closely related to or in Collingsworth
investigative work on behalf of
Conrad & Scherer.
Bates
Number Redacted
applicable) Log?
Form
witness and portions discussing request by Email from William Scherer to
Witness Bribery; Suborning Colombian witness for payment of legal William R. Richard Drath regarding
Perjury fees are closely related to or in Scherer, III investigative work on behalf of
furtherance of the alleged crimes of Conrad & Scherer.
Email chain from Pauline Koper to
Witness Bribery; Suborning Colombian witness for payment of legal
6253 CSPRIV453279 AWP Withheld Crime-Fraud Exception 4-5; 06/01/2011 Pauline Koper William Scherer regarding case CSPRIV453279
Perjury fees are closely related to or in
strategy.
Email between Collingsworth and co-
counsel; portion pertaining to issues with
funding for Colombian witness is closely Email from Terrence Collingsworth
Witness Bribery; Suborning related to or in furtherance of the alleged Terry to Gary Falkowitz, Michael Hugo,
Perjury crimes of witness bribery and suborning Collingsworth Fred Rosenthal, and Jerrold Parker
perjury and should be produced; regarding case strategy.
product

has been satisfied with regard to this
Witness Bribery; Suborning consultant, his identity, the work Terrence
6258 CSPRIV453293 AWP Withheld Crime-Fraud Exception 4-5; 06/14/2011 Collingsworth to William Scherer CSPRIV453293
Perjury performed, and payments made; this Collingsworth
the work performed (as well as discusses
request by Colombia witness for
assistance with legal fees), is closely
perjury, and should be produced

invoices in connection with testimony of Email from Terrence Collingsworth
6285 CSPRIV458855 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 07/23/2012 M. Carlson J. Carrera to Mark Carlson regarding case CSPRIV458855
or in furtherance of the alleged crimes of preparation.

invoices in connection with testimony of Email from Terrence Collingsworth
6290 CSPRIV458869 AWP Withheld Crime-Fraud Exception Colombian witness are closely related to 4-5; 07/03/2012 Mark Carlson Joseph Carrera to Mark Carlson regarding case CSPRIV458869
or in furtherance of the alleged crimes of preparation.

Drummond Special Master R&R On Crime Fraud in Camera Review Exhibit B R 633-2

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Case 2:11-cv-03695-RDP Document 633-2 Filed 06/01/20 Page 1 of 17 FILED

2020 Jun-01 AM 10:29

Ledger of C&S expenses; entries reflecting

Internal C&S communication and

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication; portions

Internal C&S communication discussing or

Internal C&S communication discussing or

Ledger of C&S expenses reflecting security

Email communication between

Email chain from Terrence

Email from Mark Carlson to

Email from Terrence Collingsworth,

Email between Collingsworth and Alber Va

Email communication between

C&S attorney timesheet; version provided

C&S attorney timesheet; version provided

C&S attorney timesheet; version provided

C&S attorney timesheet; version provided

C&S attorney timesheet; version provided

C&S attorney timesheet; entries reflecting

Chart of C&S expenses; entries reflecting

Chart of expenses; entries reflecting

Chart of PWA expenses; entries related to

Chart of C&S expenses; entries reflecting

Chart of C&S expenses; entries reflecting

Chart of C&S expenses; entries reflecting

Chart of C&S expenses; entries reflecting

Chart of C&S expenses; entries reflecting

Summary chart of C&S expenditures;

Summary chart of C&S expenditures;

Summary chart of C&S expenditures;

Summary chart of C&S expenditures;

Summary chart of C&S expenditures;

Chart of C&S expenses; entries reflecting

Receipt or document evidencing payment

Receipt or document evidencing payment

Confirmation of payment from C&S to

Internal C&S communication discussing,

Chart of C&S expenses or payments;

Chart of C&S expenses or payments;

Chart of C&S expenses or payments;

C&S attorney timesheet; entries reflecting

Redacted email with attachments

Internal C&S email communication;

Email communication among