Differences

This shows you the differences between two versions of the page.

Link to this comparison view

Both sides previous revisionPrevious revision
Next revision		Previous revision
Last revisionBoth sides next revision
supplemental_discovery [2016/10/10 04:25] – [Defense Complaints] adds link Carlos Pedrazasupplemental_discovery [2018/06/26 22:18] – [Defense Complaints] edit for clarity Carlos Pedraza
Line 68: Line 68:
  
 Throughout discovery, Loeb has asserted that many of the documents and communication sought by the defense are protected by privilege, such as plaintiffs' communications with their attorneys.(([[https://www.law.cornell.edu/wex/attorney-client_privilege|Attorney-Client Privilege, Legal Information Institute]], Cornell University School of Law, retrieved 10/7/16.)) Throughout discovery, Loeb has asserted that many of the documents and communication sought by the defense are protected by privilege, such as plaintiffs' communications with their attorneys.(([[https://www.law.cornell.edu/wex/attorney-client_privilege|Attorney-Client Privilege, Legal Information Institute]], Cornell University School of Law, retrieved 10/7/16.))
 +
 +{{page>fact check}}
  
 But the defense specifically sought communications, not with their attorneys but among the plaintiffs themselves. Ranahan asked Loeb's Grossman if the plaintiffs were continuing to assert "communications between non‐lawyers at CBS and Paramount about the lawsuit are covered by a 'comment [sic] interest' privilege. … If you are standing by this, please provide the authority for this."((Email from Erin Ranahan, Winston & Strawn, to David Grossman, Loeb & Loeb, 9/26/16.)) But the defense specifically sought communications, not with their attorneys but among the plaintiffs themselves. Ranahan asked Loeb's Grossman if the plaintiffs were continuing to assert "communications between non‐lawyers at CBS and Paramount about the lawsuit are covered by a 'comment [sic] interest' privilege. … If you are standing by this, please provide the authority for this."((Email from Erin Ranahan, Winston & Strawn, to David Grossman, Loeb & Loeb, 9/26/16.))
Line 79: Line 81:
 </WRAP> </WRAP>
  
-In his emailed reply, Grossman told Ranahan the common interest discussion to which she referred was only about whether the principle extended to discussions taking place before the suit was filed. "I believe that it does," Grossman wrote. "Purely non‐legal communications … would likely not fall under that category. However, I don't believe any documents [that] have been withheld that fall into that latter category."((Email from David Grossman, Loeb & Loeb, to Erin Ranahan, Winston & Strawn, 9/26/16.))+In his emailed reply, Grossman told Ranahan the common interest discussion to which she referred was only about whether the principle extended to discussions taking place before the suit was filed. "I believe that it does," Grossman wrote. "Purely non‐legal communications … would likely not fall under that category. However, I don't believe any documents have been withheld that fall into that latter category."((Email from David Grossman, Loeb & Loeb, to Erin Ranahan, Winston & Strawn, 9/26/16.))
  
 === Privilege Log === === Privilege Log ===