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supplemental_discovery [2016/10/10 20:26] – adds fact check box Carlos Pedrazasupplemental_discovery [2018/06/26 22:18] – [Defense Complaints] edit for clarity Carlos Pedraza
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 </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 ===