Mr. Sturdy,
We previously requested that you let us know whether you redacted any pages from any of the individually-named Defendants' personnel files in their entireity. To date, we have not received your response. Accordingly, we hereby request that you provide us with a "privilege log"pursuant to Fed. R. Civ. P. 26(b)(5) regarding your assertion of a privilege regarding the redacted material.
We will forward a cover letter (hard copy) via postal mail to your attention.
---------- Forwarded message ----------
From:
Nick Hadous <nhadous@hadousco.com>Date: Tue, Jan 24, 2012 at 11:27 AM
Subject: Defendants' Personnel Files
To: Patrick Sturdy <
psturdy@cmda-law.com>, "Jeffrey R. Clark" <
jclark@cmda-law.com>
Cc: Haytham Faraj <
haytham@puckettfaraj.com>
Mr. Sturdy,
You previously provided us with the individually-named Defendants' personnel files. You identified these as "redacted" personnel files. Were any pages redacted in their entirety (i.e., pulled from the file and not included in the disclosure?)
Cordially,
Nick
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