EXHIBIT P EFTA00028927

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Email and letter The law enforcement ot!) David Boies, Stan communications re law |Pottinger, Sigrid enforcement investigation MeCawley, Paul Cassell, Brad Edwards McCawley, Paul Cassell, Brad Edwards Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated ito lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). This categorical entry is regarding correspondence re the currently ongoing criminal investigation of Defendant and others. EFTA00028928