EXHIBIT B · Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 1 of 74 Honeywell Plan...
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EXHIBIT B Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 1 of 74
Transcript of EXHIBIT B · Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 1 of 74 Honeywell Plan...
EXHIBIT B
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 1 of 74
Honeywell Plan Defendants' May 13, 2008 Supplemental Privilege Log
Allen, et al. v. Honeywell Retirement Earnings Plan, et al. (D. Ariz., CV04-0424 PHX ROS)
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 1 1/1/1976 Handwritten notes reflecting legal analysis re: merger of
Garrett and Signal plans.No Attorney-Client RDebevoise & Plimpton*
2 3/12/1982 Letter reflecting mental impressions of counsel and providing advice re: amendments to the retirement plan and severance plan changes.
No Attorney-Client Gordon, David* Leinbach, Charles*
3 7/9/1982 Letter enclosing information in furtherance of representation re: amendment to Garrett plan.
No Attorney-Client N/AGordon, David* Leinbach, Charles*
4 7/12/1982 Draft plan documents and board resolutions reflecting legal analysis and advice re: proposed amendments to Garrett plans.
No Attorney-Client RO'Melveny & Myers*
5 9/10/1982 Letter transmitting information in furtherance of representation re: amendment to Garrett retirement plan and IRS approval.
No Attorney-Client ROhlund, Marie Gordon, David*
6 10/8/1982 Letter enclosing information prepared in furtherance of representation re: proposed Garrett plan amendments.
No Attorney-Client R Leinbach, Charles* Gordon, David*
7 11/17/1982 Letter and memorandum containing legal analysis and advice re: Garrett severance plan amendments.
No Attorney-Client O Gordon, David* Milligan, Jack Lachter, Jack
Kong, Loong
Tritt, Clyde*
8 11/17/1982 Letter containing legal analysis and advice re: Garrett severance plan.
No Attorney-Client O Gordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Tritt, Clyde*
9 1/1/1983 Draft plan amendment containing mental impressions and advice of counsel re: Signal plan amendment history.
No Attorney-Client RDebevoise & Plimpton*
10 3/15/1983 Letter and attached memorandum providing legal analysis and advice re: Garrett plan amendments.
No Attorney-Client N/ALeinbach, Charles* Gordon, David*
Page 1 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 2 of 74
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No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 11 3/23 /1983 Memo relaying legal advice and information in
furtherance of representation re: Garrett severance plan adjustments.
HW0055630 HW0055630 Yes Attorney-Client F,E,O Milligan, Jack I.R. Managers
Benefits Administrators
Allyn, B.
Bardon, Gwen
Bailey, Claire
Botiller, Ted
Bromley, Don
Cortine, T.
Close, Earl
Cudahy, Joan
DeKimpe, Lois
Donovan, Tom
Ellery, Fenn
Flanagan, Norma
Grady, Dan
Kloster, Richard
Mitchell, Francis
Moore, Edna
Bouzan, Paul
Dunaway, R.
Glover, Ed
Gordon, David*
Hayes, D.
Lachter, Jack
Leinbach, Charles*
McLeod, Jim
Parker, R.
12 5/4/1983 Notes reflecting legal strategy and ongoing assignments re: severance plan and SBA offset.
No Attorney-Client F, RO'Melveny & Myers*
13 6/15/1983 Letter enclosing draft memo containing legal analysis re: proposed amendments to Garrett Severance Plan.
No Attorney-Client OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
14 6/15/1983 Letter enclosing draft memo containing legal analysis re: proposed amendments to Garrett Severance Plan.
No Attorney-Client OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Page 2 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 3 of 74
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No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 15 6/15/1983 Letter and attached draft memorandum containing legal
analysis re: severance plan benefit structure.No Attorney-Client F, OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Tritt, Clyde*
16 6/15/1983 Letter and attached draft memorandum containing legal analysis and attorney-client communication re: severance plan benefit structure.
No Attorney-Client F, OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Tritt, Clyde*
17 6/15/1983 Letter and attached draft memorandum containing legal analysis and attorney-client communication re: severance plan benefit structure.
No Attorney-Client F, OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Tritt, Clyde*
18 6/15/1983 Letter and attached draft memorandum containing legal analysis and attorney-client communication re: severance plan benefit structure.
No Attorney-Client F, OGordon, David* Milligan, Jack Leinbach, Charles*
Lachter, Jack
Kong, Loong
Tritt, Clyde*
19 6/15/1983 Draft memo containing legal analysis re: proposed amendments to Garrett Severance Plan.
No Attorney-Client RO'Melveny & Myers*
20 9/1/19 83 Letter containing attorney-client communication re: IRS determination re: plan amendments.
No Attorney-Client F\ Gordon, David* Leinbach, Charles*
21 9/17/1983 Letter seeking legal advice re: IRS determinations re: Garrett plan amendments.
No Attorney-Client FLeinbach, Charles* Gordon, David*
22 9/17/1983 Letter and attachment reflecting attorney-client communications re: IRS determination re: plan amendment.
No Attorney-Client F, RGordon, David* Leinbach, Charles*
23 9/17/1983 Letter and attachment reflecting attorney-client communications re: IRS determination re: plan amendment.
No Attorney-Client F, R Gordon, David* Leinbach, Charles*
24 10/15/1983 Notes reflecting legal analysis re: timetable for restructuring of Garrett plans.
No Attorney-Client F, RDebevoise & Plimpton*
Page 3 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 4 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 25 10/26/1983 Letter and draft proposal reflecting attorney-client
communication and requesting information in furtherance of representation re: annuity purchase quotation.
No Attorney-Client F, OCoffey, William Garcia, A. Duff, David*
Pinzur, Laurence
26 10/28/1983 Letter and memo reflecting legal advice and analysis re: severance plan restructuring.
No Attorney-Client F, U, RGordon, David*
27 10/28/1983 Information provided at the request of counsel and in furtherance of representation re: severance plan restructuring options.
No Attorney-Client F, O, RLachter, Jack Gordon, David*
28 10/28/1983 Letter reflecting legal advice and analysis re: severance plan restructuring.
No Attorney-Client F, UGordon, David*
29 11/2/1983 Letter containing legal advice and analysis and enclosing information in furtherance of representation re: severance and retirement plan documents.
No Attorney-Client F, O, R, Gordon, David* Kong, Loong
30 12/1/1983 Memo providing legal analysis and mental impressions of counsel re: proposed changes to Signal retirement plan.
No Attorney-Client F, E, O Gordon, David* Bouzan, Paul
Close, Earl
Glover, Ed
Milligan, Jack
McLeod, Jim
Leinbach, Charles*
Kong, Loong
Lachter, Jack
Duff, David*
Ryan, Kathy*
Coffey, William
Rauch, Richard
31 12/15/1983 Draft plan document reflecting legal advice and strategy re: Garrett retirement plan amendment.
No Attorney-Client F, RDebevoise & Plimpton*
32 12/19/1983 Letter containing legal advice re: computation of service under retirement plan.
No Attorney-Client FGordon, David* Leinbach, Charles*
33 12/19/1983 Draft plan documents reflecting legal advice re: Garrett retirement plan amendments.
No Attorney-Client F, RO'Melveny & Myers*
Page 4 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 5 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 34 12/27/1983 Letter containing attorney-client communication re: draft
Signal retirement plan.No Attorney-Client F, O, R Gordon, David* Lachter, Jack McLeod, Jim
35 12/28/1983 Letter containing legal advice re: revised draft amendment to Signal savings plan trust agreement.
No Attorney-Client F, ODuff, David* Rauch, Richard
Arms, Brewster*
Gordon, David*
Coffey, William
Metzger, Warren
36 12/29/1983 Memorandum providing legal analysis and containing mental impressions of counsel re: draft Signal retirement plan.
No Attorney-Client F, OGordon, David* Bouzan, Paul
Close, Earl
Glover, Ed
Milligan, Jack
McLeod, Jim
Leinbach, Charles*
Kong, Loong
Lachter, Jack
Duff, David*
Ryan, James*
Coffey, William
Rauch, Richard
37 12/29/1983 Letter and attachments conveying legal advice and recommendation re: Prudential annuity agreement with Signal Savings and Stock Purchase Plan.
No Attorney-Client F, OGordon, David* Norton, R. Rauch, Richard
Sanborn, III, W.
Grover, J.
Norton, R.
Lachter, Jack
Duff, David*
Franklin, J.
Metzger, Warren
Hudgens, C.
Rauch, Richard
Page 5 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 6 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 38 3/5/1984 Fax and attachment containing mental impressions of
counsel and legal advice re: Garrett plan amendments.No Attorney-Client F, P Duff, David* Coffey, William
39 7/9/1984 Letter providing legal advice and impressions of counsel re: draft addition to Signal retirement plan.
No Attorney-Client F, PGordon, David* Leinbach, Charles*
40 7/26/1984 Notes reflecting mental impressions of counsel and legal advice re: meeting re: retirement plan.
No Attorney-Client F, D, PO'Melveny & Myers*
41 8/9/1984 Letter containing attorney-client communications and legal analysis and mental impressions of counsel re: proposed revision to the Signal Retirement Plan.
No Attorney-Client F, PGordon, David* Ryan, Kathy*
42 8/12/1984 Handwritten notes reflecting communications with counsel for purposes of developing legal advice and strategy re: claim for SBA benefits.
HW0054941 HW0054971 Yes Attorney-Client FO'Neill, Harry*
43 8/21/1984 Fax and attachment providing information in furtherance of representation and legal advice re: IRS rules for computation of vesting service.
No Attorney-Client FRyan, Kathy* Coffey, William
44 10/16/1984 Document reflecting mental impressions of counsel re: draft Signal retirement plan.
No Attorney-Client F, PCovington & Burling*
45 10/22/1984 Letter and attachments providing legal advice and mental impressions of counsel re: Garrett Retirement Plan.
No Attorney-Client F, PGordon, David*
Leinbach, Charles*
Leinbach, Charles*
Gordon, David*
46 10/29/1984 Letter requesting information in furtherance of representation and legal advice re: deferred retirement benefits.
No Attorney-Client FLeinbach, Charles* Gordon, David*
47 6/25/1985 Letter reflecting legal advice re: revised amendment to Signal savings and stock purchase plan.
No Attorney-Client N/A Arms, Brewster* Allen, W.*
Perry, R.
Hamilton, Steve*
Woods, J.
Leinbach, Charles*
48 10/28/1985 Handwritten notes reflecting mental impressions of counsel re: Signal retirement plan.
No Attorney-Client F, PDebevoise & Plimpton*
49 12/4/1985 Memo and attachments containing information sent in furtherance of representation re: incorporation of Signal retirement plan with Garrett plan.
No Attorney-Client F, P Bennett, T. Gordon, David*
Page 6 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 7 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 50 1/22/1986 Memo containing legal advice and mental impressions
of counsel re: proposed Signal retirement plan amendments.
No Attorney-Client FDuff, David* The Administrative Committee Under the Signal Companies, Inc. Retirement Plan
Arms, Brewster*
Freundlich, B. David
Coffey, William
51 1/22/1986 Memo containing legal advice and mental impressions of counsel re: proposed Signal retirement plan amendments.
No Attorney-Client FDuff, David* The Administrative Committee Under the Signal Companies, Inc. Retirement Plan
Arms, Brewster*
Freundlich, B. David
Coffey, William
52 4/8/1986 Letter providing legal advice re: draft Signal plan amendments.
No Attorney-Client E, OTaylor, L.* Breeding, J.
Brindley, Elizabeth
Cannon, C.
Czwalga, E.
Donroe, F.
Farrell, Mark
Gambrel, A.
Howland, Gerry*
Kehrer, A.
Pinzur, Laurence
Reed, P.
Shaw, Jr., Charles
Smith, C.
Waters, H.
Yarmchuk, Robert
Coffey, William
Duff, David*
Kronheim, Steven*
53 4/8/1986 Draft reflecting mental impressions of counsel and legal advice re: Signal retirement plan amendments.
No Attorney-Client FDuff, David* The Administrative Committee Under the Signal Companies, Inc. Retirement Plan
54 1/20/1987 Letter containing attorney-client communication re: IRS HW0055631filings for Signal retirement plan and IRS determination letters.
Yes Attorney-Client F, RGordon, David* Catapano-Friedman, R.
Page 7 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 8 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 55 9/19/1995 Fax containing attorney-client communications re:
potential SBA claims.No Attorney-Client FWigle, James* O'Keefe, Mary Lou
Mercer, Peter
McGovern, Patrick*
56 9/19/1995 Fax containing attorney-client communications re: potential SBA claims.
No Attorney-Client FWigle, James* Snethen, Joe
57 9/19/1995 Fax containing attorney-client communications re: potential SBA claims.
No Attorney-Client FWigle, James* Snethen, Joe
58 9/19/1995 Fax containing attorney-client communications re: potential SBA claims.
No Attorney-Client FWigle, James* O'Keefe, Mary Lou
Mercer, Peter
McGovern, Patrick*
59 10/6/1995 Email seeking legal advice re: communications to employees re: SBA offset.
No Attorney-Client F, EDonovan, Tom Chapman, Craig
Goulet, Tom
O'Keefe, Mary Lou
Payne, Jean
Wigle, James*
60 10/9/1995 Email containing legal advice and mental impressions of counsel re: potential SBA questions and claims.
No Attorney-Client F, EWigle, James* Bocick, E. Anderson, Vance*
McGovern, Patrick*
O'Keefe, Mary Lou
Sabol, Joy
Chapman, Craig
Gore, Joe*
61 10/10/1995 Email chain containing attorney-client communications re: communications to employees re: SBA offset.
No Attorney-Client FWigle, James* Donovan, Tom
O'Keefe, Mary Lou
Chapman, Craig
62 10/10/1995 Email chain reflecting attorney-client communications re: communications to employees re: SBA.
HW0031561 HW0031571 Yes Attorney-Client FWigle, James* Donovan, Tom
O'Keefe, Mary Lou
Chapman, Craig
Page 8 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 9 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 63 10/12/1995 Email forwarding instructions and legal advice from
counsel re: communications with SBA plan participants.No Attorney-Client FArbolida, Max Chapman, Craig
Shaw, Don
Anderson, Vance*
McGovern, Patrick*
64 10/12/1995 Email chain and attachment reflecting legal advice re: communications to employees re: SBA.
HW0031582 HW0031585 Yes Attorney-Client F Wigle, James* Snethen, Joe
Donovan, Tom
Anderson, Vance*
McGovern, Patrick*
Arbolida, Max
Gore, Joe*
65 10/13/1995 Fax and attachments containing information provided at the request of counsel in furtherance of representation re: SBA actuarial analysis.
No Attorney-Client F, ODonovan, Tom Kong, Loong
66 10/13/1995 Email and attachment containing attorney-client communications re: SBA offset calculation.
HW0032566 HW0032571 Yes Attorney-Client F, ODonovan, Tom Rojas, Maureen Wigle, James*
Snethen, Joe
Chapman, Craig
O'Keefe, Mary Lou
67 10/16/1995 Email containing attorney-client communications and seeking legal analysis re: potential SBA claims.
No Attorney-Client F, EO'Keefe, Mary Lou Hawkins, Russ Chapman, Craig
Donovan, Tom
Payne, Jean
Rojas, Maureen
Wigle, James*
68 10/16/1995 Handwritten notes reflecting conference with counsel and legal strategy re: SBA issue.
No Attorney-Client FChapman, Craig
69 10/16/1995 Handwritten notes reflecting attorney-client communications re: communications to employees re: SBA.
No Attorney-Client FChapman, Craig
70 10/17/1995 Email and attachment reflecting attorney-client communications and information prepared at the request of counsel re: SBA plan amendment.
No Attorney-Client FDonovan, Tom Rojas, Maureen Snethen, Joe
Chapman, Craig
O'Keefe, Mary Lou
Wigle, James*
Page 9 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 10 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 71 10/17/1995 Email and attachment reflecting legal analysis and
mental impressions of counsel re: potential SBA claims.No Attorney-Client FWigle, James* Chapman, Craig
Donovan, Tom
Rojas, Maureen
72 10/17/1995 Email and attachment reflecting legal advice re: proposed communications to employee focus groups re: SBA.
No Attorney-Client FWigle, James* Chapman, Craig
Donovan, Tom
Rojas, Maureen
73 10/19/1995 Email chain containing attorney-client communications re: communications to employees re: SBA.
No Attorney-Client F Donovan, Tom Wigle, James* Chapman, Craig
Rojas, Maureen
74 10/23/1995 Handwritten notes reflecting attorney-client communications re: communications to employees re: SBA.
No Attorney-Client F Chapman, Craig
75 10/25/1995 Email containing attorney-client communication re: communications to employees re: SBA.
No Attorney-Client F, EPoulin, Carla Adair, Jerry* Hawkins, Russ
Chapman, Craig
76 10/25/1995 Email chain containing attorney-client communication re: communications to employees re: SBA.
No Attorney-Client F, EChapman, Craig Poulin, Carla Adair, Jerry*
Snethen, Joe
Hawkins, Russ
77 10/26/1995 Fax cover sheet and email seeking legal analysis and mental impressions of counsel re: potential SBA claims.
No Attorney-Client F, E O' K eefe, Mary Lou Hawkins, Russ Wigle, James*
Chapman, Craig
Rojas, Maureen
Donovan, Tom
Payne, Jean
Goulet, Tom
Arbolide, Max
78 10/27/1995 Email chain containing attorney-client communication re: communications to employees re: SBA.
No Attorney-Client F, E Donovan, Tom Chapman, Craig
O'Keefe, Mary Lou
Shaw, Don
Payne, Jean
Rojas, Maureen
Wigle, James*
Sabol, Joy
Page 10 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 11 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 79 11/2/1995 Email seeking legal analysis and advice re: stand alone
SBA statement.No Attorney-Client F, EPoulin, Carla Adair, Jerry*
Snethen, Joe
Edwards, Dale
Kitchell, Carol
80 11/7/1995 Email seeking legal advice re: communications to employees re: SBA.
No Attorney-Client F, ERojas, Maureen Adair, Jerry*
Snethen, Joe
O'Connor, Collen
Chapman, Craig
Sabol, Joy
81 11/7/1995 Email reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F, E, ORojas, Maureen Snethen, Joe
Adair, Jerry*
O'Connor, Collen
Chapman, Craig
Sabol, Joy
Shutler, Gary
Yarmchuk, Robert
82 11/7/1995 Email and attachment reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F Rojas, Maureen Adair, Jerry*
Snethen, Joe
83 11/7/1995 Email reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F, ERojas, Maureen Snethen, Joe
Adair, Jerry*
O'Connor, Collen
Chapman, Craig
Sabol, Joy
84 11/7/1995 Email reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F, ERojas, Maureen Adair, Jerry*
Snethen, Joe
O'Connor, Collen
Chapman, Craig
Sabol, Joy
85 11/8/199 5 Email reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F, E Adair, Jerry* Snethen, Joe
Rojas, Maureen
O'Connor, Collen
Chapman, Craig
Sabol, Joy
86 11/8/1995 Email reflecting legal advice and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client F, EAdair, Jerry* Snethen, Joe
Rojas, Maureen
O'Connor, Collen
Chapman, Craig
Sabol, Joy
Page 11 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 12 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 87 11/13/1995 Email containing attorney-client communication re:
potential litigation involving Garrett SBA.No Attorney-Client F Wigle, James* Arbolida, Max
Shaw, Don
O'Keefe, Mary Lou
Donovan, Tom
Chapman, Craig
88 11/13/1995 Email chain containing attorney-client communications re: potential litigation involving Garrett SBA.
No Attorney-Client F Wigle, James* Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Shaw, Don
Arbolida, Max
89 11/13/1995 Email seeking legal advice re: communications to employees re: SBA.
HW0031961 HW0031963 Yes Attorney-Client F, ERojas, Maureen Adair, Jerry*
Snethen, Joe
Poulin, Carla
Chapman, Craig
Sabol, Joy
90 11/16/1995 Email chain containing attorney-client communications and reflecting legal advice re: communications to employees re: SBA.
No Attorney-Client F, ERojas, Maureen Foster, Chuck
Nicholls, Mark
Shaw, Don
Arbolida, Max
Adair, Jerry*
O'Connor, Collen
Snethen, Joe
Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Payne, Jean
Wigle, James*
Hultquist, Kyle
Sabol, Joy
Mercer, Peter
Page 12 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 13 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure91 11/17/1995 Email chain reflecting legal advice re: communications
to employees re: SBA offset.No Attorney-Client F, ERojas, Maureen Foster, Chuck
Nicholls, Mark
Arbolida, Max
Shaw, Don
Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Payne, Jean
Goulet, Tom
Wigle, James*
Hultquist, Kyle
Sabol, Joy
Mercer, Peter
92 11/17/1995 Email chain reflecting legal advice re: communications to employees re: SBA.
No Attorney-Client F, ERojas, Maureen Bendino, Marilyn
Bohne, Jeff
Chapman, Craig
Fincher, Dick
Flannagan, Gary
Foster, Chuck
Galloway, Zena
Johnson, Lisa
Kepner, Mary
Livermore, Lucy
Martinez, Joel
Mattick, Susan
Nicholls, Mark
Nicoson, Cookie
Oliver, Kendall
Parsons, Sally
Page 13 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 14 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 93 11/17/1995 Email chain containing attorney-client communications
and reflecting legal advice re: communications to employees re: SBA.
No Attorney-Client F, E Rojas, Maureen Foster, Chuck
Nicholls, Mark
Shaw, Don
Arbolida, Max
Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Payne, Jean
Goulet, Tom
Wigle, James*
Hultquist, Kyle
Sabol, Joy
Mercer, Peter
94 11/20/1995 Email chain containing attorney-client communications and reflecting legal advice re: communications to employees re: SBA.
No Attorney-Client F, ESnethen, Joe
Rojas, Maureen
Bryant, Stacey
Foster, Chuck
Nicholls, Mark
Shaw, Don
Arbolida, Max
Adair, Jerry*
O'Connor, Collen
Snethen, Joe
Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Payne, Jean
Goulet, Tom
Wigle, James*
Hultquist, Kyle
Sabol, Joy
Mercer, Peter
95 12/4/1995 Email containing mental impressions of counsel and legal advice re: SBA video.
No Attorney-Client FAdair, Jerry* Chapman, Craig
96 12/4/1995 Email containing legal advice re: communications to employees re: SBA.
No Attorney-Client FAdair, Jerry* Chapman, Craig
Page 14 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 15 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure97 12/11/1995 Email containing attorney-client communications re:
SBA offset.No Attorney-Client FChapman, Craig Adair, Jerry*
Edwards, Dale
Snethen, Joe
O'Keefe, Mary Lou
Shaw, Don
Rojas, Maureen
Wigle, James*
Edwards, Dale
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
98 12/11/1995 Email containing attorney-client communications re: SBA communication to employees.
No Attorney-Client FChapman, Craig Adair, Jerry*
Snethen, Joe
Edwards, Dale
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
99 12/11/1995 Email containing attorney-client communications re: SBA offset.
No Attorney-Client FChapman, Craig Adair, Jerry*
Edwards, Dale
Snethen, Joe
O'Keefe, Mary Lou
Shaw, Don
Rojas, Maureen
Wigle, James*
100 12/11/1995 Email reflecting attorney-client communication and mental impressions of counsel re: SBA communication to employees.
No Attorney-Client FChapman, Craig Adair, Jerry*
Snethen, Joe
Edwards, Dale
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
101 12/11/1995 Email requesting legal advice re: communications to employees re: SBA.
HW0031885 HW0031887 Yes Attorney-Client FChapman, Craig Adair, Jerry*
Edwards, Dale
Snethen, Joe
O'Keefe, Mary Lou
Shaw, Don
Rojas, Maureen
Wigle, James*
Page 15 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 16 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 102 12/11/1995 Email containing attorney-client communication re:
feedback from employee re: communications to employees re: SBA.
HW0031891 HW0031901 Yes Attorney-Client FChapman, Craig Edwards, Dale
Snethen, Joe
Adair, Jerry*
Shaw, Don
Wigle, James*
O'Keefe, Mary Lou
Rojas, Maureen
103 12/11/1995 Email containing attorney-client communication re: feedback from employee re: communications to employees re: SBA.
No Attorney-Client F Edwards, Dale
Chapman, Craig
Chapman, Craig
Adair, Jerry*
Snethen, Joe
Edwards, Dale
Snethen, Joe
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
104 12/11/1995 Email containing attorney-client communication re: feedback from employee re: communications to employees re: SBA.
HW0031902 HW0031905 Yes Attorney-Client F Chapman, Craig Adair, Jerry*
Edwards, Dale
Snethen, Joe
O'Keefe, Mary Lou
Shaw, Don
Rojas, Maureen
Wigle, James*
105 12/11/1995 Email containing attorney-client communication re: feedback from employee re: communications to employees re: SBA.
HW0031914 HW0031914 Yes Attorney-Client FChapman, Craig Edwards, Dale
Snethen, Joe
Adair, Jerry*
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
106 12/11/1995 Email containing attorney-client communication re: feedback from employee re: communications to employees re: SBA.
HW0056759 HW0056769 Yes Attorney-Client FChapman, Craig Edwards, Dale
Snethen, Joe
Adair, Jerry*
Shaw, Don
Wigle, James*
O'Keefe, Mary Lou
Rojas, Maureen
107 12/18/1995 Email providing legal advice for draft presentation re: SBA offset.
No Attorney-Client F Adair, Jerry* Chapman, Craig Snethen, Joe
Edwards, Dale
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
Page 16 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 17 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 108 12/18/1995 Email containing legal advice re: communications with
employees re: SBA.No Attorney-Client FAdair, Jerry* Chapman, Craig Snethen, Joe
Edwards, Dale
O'Keefe, Mary Lou
Rojas, Maureen
Wigle, James*
Shaw, Don
109 1/1/1996 Chart containing analysis prepared at the request of counsel for purposes of developing legal advice and in furtherance of representation re: individual benefits calculations for potential lawsuit
No Attorney-Client; F, O, LWork Product
Denlinger, Kurt
110 1/22/1997 Handwritten notes reflecting legal re: IRS determination re: AlliedSignal retirement plan.
HW0055208 HW0055028 Yes Attorney-Client FKronheim, Steven*
111 6/19/1997 Email seeking legal advice re: treatment of SBA accounts for rehired employees.
HW0031839 HW0031841 Yes Attorney-Client F, ESowecke, Tom Greenman, Jane* Fincher, Dick
112 7/10/1997 Email communication from counsel reflecting legal advice re: proposed SBA amendments.
Yes Attorney-Client F, ESowecke, Tom Greenman, Jane* Fincher, Dick
113 5/14/1999 Email providing information and analyzing benefits at request of counsel for purpose of providing legal advice and strategy re: ADEA lawsuit.
No Attorney-Client N/AConte, Carol Rusin, P. Greenman, Jane*
Denlinger, Kurt
114 9/17/1999 Email and attached presentation containing attorney-client communications re: proposed design changes to SBA.
No Attorney-Client F, E, ORosenberg, Melanie Mathis, Kathleen
Snethen, Joe
Edwards, Dale
Payne, Jean
Covert, Kevin*
Greenman, Jane*
Denlinger, Kurt
Page 17 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 18 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 115 9/20/1999 Email with handwritten notes and attachment seeking
legal advice re: SBA alternatives.No Attorney-Client F, EMathis, Kathleen Greenman, Jane*
Covert, Kevin*
Snethen, Joe
Edwards, Dale
Rosenberg, Melanie
Payne, Jean
Mercer, Peter
116 9/20/1999 Email sending draft presentation to counsel for purpose of securing legal advice re: proposed SBA alternatives under Signal Retirement Plan.
No Attorney-Client F, E Mathis, Kathleen Greenman, Jane*
Covert, Kevin*
Snethen, Joe
Edwards, Dale
Rosenberg, Melanie
117 3/14/2000 Fax transmitting information prepared at the request of counsel for purposes of securing legal advice re: benefits calculations.
HW0032511 HW0032514 Yes Attorney-Client F, O Denlinger, Kurt Gangone, Marie*
118 3/31/2000 Handwritten notes reflecting legal advice re: communications to employees re: proposed plan amendments.
HW0031262 HW0031264 Yes Attorney-Client FChapman, Craig
119 4/4/2000 Email chain and attachment reflecting legal advice re: draft SBA communication.
No Attorney-Client F, E, O Chapman, Craig Smith, C. Mathis, Kathleen
Burnelko, Cindy
Payne, Jean
120 4/4/2000 Email chain containing legal advice re: draft communication re: SBA.
No Attorney-Client F, EChapman, Craig Clarke, Allen*
Payne, Jean
121 4/10/2000 Handwritten notes reflecting legal advice re: communications to employees re: proposed plan amendments.
No Attorney-Client F, E Chapman, Craig
Page 18 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 19 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 122 4/13/2000 Email providing benefits analysis to counsel for
purposes of developing legal advice and strategy re: effect of proposed plan amendment and ADEA claims.
No Attorney-Client N/ADenlinger, Kurt Mathis, Kathleen Burnelko, Cindy
Covert, Kevin*
Marcotte, Brian
Murphy, Blake
Conte, Carol
Sher, F.
D'Ariano, Frank
123 4/13/2000 Email chain and attachment seeking legal advice re: communications to participants re: SBA plan.
No Attorney-Client F, E, O Chapman, Craig Chapman, Craig
Clarke, Allen*
Mathis, Kathleen
Burnelko, Cindy
Murphy, Blake
Rojas, Maureen
Payne, Jean
Saperstein, Steven
124 4/13/2000 Email chain and attachment seeking legal advice re: communications to participants re: SBA plan.
No Attorney-Client F, OChapman, Craig Chapman, Craig
Clarke, Allen*
Mathis, Kathleen
Burnelko, Cindy
Murphy, Blake
Rojas, Maureen
125 4/14/2000 Email from and forwarding correspondence by counsel re: benefits analysis for purpose of developing legal advice and strategy.
No Attorney-Client F, O Covert, Kevin* Denlinger, Kurt
126 4/14/2000 Email chain including request for legal advice re: draft communications re: SBA offset.
No Attorney-Client F, E, OMurphy, Blake Chapman, Craig Clarke, Allen*
Mathis, Kathleen
Burnelko, Cindy
Rojas, Maureen
Payne, Jean
Saperstein, Steven
Harris, Rita
Page 19 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 20 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 127 4/14/2000 Email chain discussing and forwarding request for legal
advice from counsel re: draft communications re: SBA offset.
No Attorney-Client F, E, O Chapman, Craig Murphy, Blake Saperstein, Steven
Mathis, Kathleen
Rojas, Maureen
Payne, Jean
128 4/14/2000 Email chain discussing and forwarding legal analysis from counsel re: SBA eligibility date.
No Attorney-Client F, EChapman, Craig Payne, Jean
Rojas, Maureen
Saperstein, Steven
Oliver, Kendall
Robles, Josie
129 4/14/2000 Email chain and attachments providing legal advice re: communications to participants re: SBA plan.
No Attorney-Client F, EClarke, Allen* Rojas, Maureen
Chapman, Craig
Mathis, Kathleen
Rojas, Maureen
Payne, Jean
Saperstein, Steven
130 4/14/2000 Email chain and attachment providing legal advice re: communications to participants re: SBA plan.
No Attorney-Client F ,E,O Clark e, Allen* Chapman, Craig
Mathis, Kathleen
Burnelko, Cindy
Murphy, Blake
Rojas, Maureen
Payne, Jean
Saperstein, Steven
131 4/24/2000 Email chain containing legal advice re: communications to employees re: proposed plan amendments.
No Attorney-Client N/AGreenman, Jane* Clarke, Allen* Chapman, Craig
Rojas, Maureen
132 4/24/2000 Emails discussing benefits analysis prepared at the request of counsel for purpose of providing legal advice and forwarding communications with counsel re: proposed plan amendments.
No Attorney-Client N/A Denlinger, Kurt Murphy, Blake Smith, C.
133 4/25/2000 Email chain containing legal advice re: communications to employees re: proposed plan amendments.
HW0031342 HW0031349 Yes Attorney-Client FGreenman, Jane* Chapman, Craig
Clarke, Allen*
Mathis, Kathleen
Marcotte, Brian
Page 20 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 21 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 134 4/25/2000 Email from counsel requesting analysis for purposes of
developing legal advice re: benefits calculations.No Attorney-Client F, OCovert, Kevin* Denlinger, Kurt Greenman, Jane*
Vine, John*
135 4/25/2000 Handwritten notes reflecting legal advice re: communications to employees re: proposed plan amendments.
HW0031300 HW0031308 Yes Attorney-Client FChapman, Craig
136 4/27/2000 E-mail chain reflecting legal advice re: communications to employees re: SBA offset.
No Attorney-Client FClarke, Allen* Chapman, Craig Greenman, Jane*
137 5/3/2000 Email forwarding draft communications to counsel for purposes of securing legal advice re: proposed amendments concerning the SBA.
No Attorney-Client N/A Chapman, Craig Mathis, Kathleen Rojas, Maureen
Clarke, Allen*
Payne, Jean
138 5/3/2000 Fax reflecting handwritten notes and legal advice from counsel re: draft SBA presentation.
No Attorney-Client FMathis, Kathleen
Clarke, Allen*
Chapman, Craig
139 5/15/2000 Email chain including request for legal advice re: draft SBA communication materials.
No Attorney-Client F, RMathis, Kathleen Rojas, Maureen
140 5/16/2000 Email correspondence responding to request from counsel for analysis re: ADEA claim and SBA amendment for purposes of developing legal advice and strategy.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt Murphy, Blake
141 5/16/2000 Email correspondence responding to request from counsel for analysis re: ADEA claim and SBA amendment for purposes of developing legal advice and strategy.
No Attorney-Client N/A Denlinger, Kurt Murphy, Blake
142 5/17/2000 Email correspondence responding to request from counsel for analysis re: ADEA claim and SBA amendment for purposes of developing legal advice and strategy.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt Murphy, Blake
143 5/19/2000 Email correspondence responding to request from counsel for analysis re: ADEA claim and SBA amendment for purposes of developing legal advice and strategy.
No Attorney-Client N/A Denlinger, Kurt Endrizzi, Jim
144 5/23/2000 Email correspondence responding to request from counsel for analysis re: SBA amendment for purposes of developing legal advice and strategy and forwarding correspondence with counsel re: same.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt
Page 21 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 22 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 145 5/24/2000 Fax providing analysis requested by counsel re: SBA
account balances for purpose of developing legal advice.
No Attorney-Client N/ADenlinger, Kurt Horne, Carolyn
146 5/24/2000 Email providing benefits analysis at the request of counsel re: potential SBA amendment for purposes of developing legal advice.
No Attorney-Client N/ADenlinger, Kurt Horne, Carolyn
Greenman, Jane*
Covert, Kevin*
Mathis, Kathleen
147 5/24/2000 Email correspondence responding to request from counsel for analysis re: SBA amendment for purposes of developing legal advice and strategy and forwarding correspondence with counsel re: same.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt
148 5/24/2000 Email from counsel requesting analysis re: SBA amendment for purposes of developing legal advice.
No Attorney-Client N/AGreenman, Jane* Denlinger, Kurt
149 5/26/2000 Email responding to request from counsel for analysis re: SBA amendment for purposes of developing legal advice.
No Attorney-Client N/ADenlinger, Kurt Horne, Carolyn
Greenman, Jane*
Mathis, Kathleen
Covert, Kevin*
Murphy, Blake
Endrizzi, Jim
150 5/26/2000 Email correspondence responding to request from counsel for analysis re: SBA amendment for purposes of developing legal advice and strategy and forwarding correspondence with counsel re: same.
No Attorney-Client N/A Murphy, Blake Denlinger, Kurt
151 5/26/2000 Email providing analysis at the request of counsel re: SBA amendment for purposes of developing legal advice.
No Attorney-Client N/ADenlinger, Kurt Horne, Carolyn
Greenman, Jane*
Covert, Kevin*
Mathis, Kathleen
152 5/31/2000 Email from counsel requesting information and analysis re: proposed SBA amendment for purposes of developing legal advice and forwarding correspondence re: same.
No Attorney-Client N/ACovert, Kevin* Denlinger, Kurt
Page 22 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 23 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 153 5/31/2000 Email correspondence responding to request from
counsel for analysis re: SBA amendment for purposes of developing legal advice and strategy and forwarding correspondence with counsel re: same.
No Attorney-Client N/ADenlinger, Kurt Horne, Carolyn
Greenman, Jane*
Mathis, Kathleen
Covert, Kevin*
Murphy, Blake
Endrizzi, Jim
154 5/31/2000 Email providing analysis at the request of counsel re: proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client N/ADenlinger, Kurt Covert, Kevin* Murphy, Blake
Endrizzi, Jim
155 5/31/2000 Email from counsel requesting information and analysis re: proposed SBA amendment for purposes of developing legal advice and forwarding correspondence re: same.
No Attorney-Client N/AHorne, Carolyn Denlinger, Kurt
Mathis, Kathleen
Murphy, Blake
Endrizzi, Jim
156 5/31/2000 Email providing analysis at the request of counsel re: proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt
157 5/31/2000 Email chain containing analysis prepared for purposes of providing legal advice re: proposed SBA amendment.
No Attorney-Client N/A Denlinger, Kurt Horne, Carolyn
Greenman, Jane*
Mathis, Kathleen
Covert, Kevin*
Murphy, Blake
Endrizzi, Jim
158 6/1/2000 Email correspondence responding to request from counsel for analysis re: SBA amendment for purposes of developing legal advice and strategy and forwarding correspondence with counsel re: same.
No Attorney-Client N/ADenlinger, Kurt Endrizzi, Jim
Murphy, Blake
159 6/2/2000 Email providing analysis at the request of counsel re: proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client N/A Endrizzi, Jim Denlinger, Kurt
Horne, Carolyn
Greenman, Jane*
Mathis, Kathleen
Page 23 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 24 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 160 6/2/2000 Email providing analysis at the request of counsel re:
proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client N/AEndrizzi, Jim Denlinger, Kurt Horne, Carolyn
Greenman, Jane*
Mathis, Kathleen
Covert, Kevin*
Murphy, Blake
161 6/26/2000 Email providing analysis at the request of counsel re: proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client N/ADenlinger, Kurt Marcotte, Brian
Covert, Kevin*
Edwards, Dale
162 7/19/2000 Email requesting information and analysis re: proposed SBA amendment for purposes of developing legal advice and forwarding correspondence re: same.
No Attorney-Client F, P, OEdwards, Dale Denlinger, Kurt
Edwards, Dale
Marcotte, Brian
Covert, Kevin*
163 7/19/2000 Email providing analysis at the request of counsel re: proposed SBA amendment for purposes of providing legal advice and forwarding correspondence re: same.
No Attorney-Client F, P, ODenlinger, Kurt Edwards, Dale Edwards, Dale
Marcotte, Brian
Covert, Kevin*
164 8/31/2000 Memo containing request for legal advice re: Prudential proposal re: SBA annuity contract.
No Attorney-Client N/ABurden, Jay Covert, Kevin*
Edwards, Dale
Greenman, Jane*
Heagstedt, J.
Kitchell, Carol
Mathis, Kathleen
Tokar, Edward
Matthews, R.
165 9/4/2000 Email from counsel requesting information and analysis for purposes of providing legal advice re: proposed SBA amendment.
No Attorney-Client F, P, E Covert, Kevin* Burnelko, Cindy
Gangone, Marie*
Mathis, Kathleen
McDonald, Cathy
Covert, Kevin*
Gangone, Marie*
Mathis, Kathleen
McDonald, Cathy
166 9/5/2000 Email from counsel requesting information and analysis for purposes of providing legal advice re: proposed SBA amendment.
No Attorney-Client F, P Covert, Kevin* Mathis, Kathleen
Gangone, Marie*
Page 24 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 25 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 167 9/5/2000 Email responding to request from counsel for
information and analysis for purposes of providing legal advice re: proposed SBA amendment and forwarding correspondence re: same.
No Attorney-Client F, P, EMcDonald, Cathy Covert, Kevin*
Burnelko, Cindy
Gangone, Marie*
Mathis, Kathleen
168 9/5/2000 Email responding to request from counsel for information and analysis for purposes of providing legal advice re: proposed SBA amendment and forwarding correspondence re: same.
No Attorney-Client F, P, ODenlinger, Kurt Covert, Kevin*
169 9/13/2000 Email chain and attachment containing attorney-client communications re: draft plan amendment.
No Attorney-Client F, P, E Chapman, Craig Mathis, Kathleen Payne, Jean
170 10/3/2000 Memo containing request for legal advice re: Prudential proposal re: SBA annuity contract.
HW0026374 HW0026378 Yes Attorney-Client N/A Burden, Jay Edwards, Dale
Mathis, Kathleen
Covert, Kevin*
Greenman, Jane*
Tokar, Edward
171 10/11/2000 Email providing information at the request of counsel re: benefits calculations and background for administrative claimant for purposes of providing legal advice and legal strategy.
No Attorney-Client F, O, RGangone, Marie* Denlinger, Kurt
172 10/11/2000 Email providing information at the request of counsel re: benefits calculations and background for administrative claimant for purposes of providing legal advice and legal strategy.
No Attorney-Client F, O, R Gangone, Marie* Denlinger, Kurt
173 11/1/2000 Memo containing request for legal advice re: Prudential proposal re: SBA annuity contract.
No Attorney-Client N/ABurden, Jay Edwards, Dale
Mathis, Kathleen
Covert, Kevin*
Greenman, Jane*
Heagstedt, J.
Tokar, Edward
Zeleney, D.
174 11/3/200 Memo containing request for legal advice re: Prudential proposal re: SBA annuity contract.
HW0026384 HW0026388 Yes Attorney-Client N/ABurden, Jay Edwards, Dale
Mathis, Kathleen
Covert, Kevin*
Tokar, Edward
Greenman, Jane*
Page 25 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 26 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 175 11/3/2000 Memo with handwritten notes containing request for
legal advice re: Prudential proposal re: SBA annuity contract.
HW0026379 HW0026383 Yes Attorney-Client N/ABurden, Jay
Mathis, Kathleen
Edwards, Dale
Mathis, Kathleen
Covert, Kevin*
Tokar, Edward
Greenman, Jane*
176 11/20/2000 Email chain containing attorney-client communications and reflecting legal advice re: communications to employees re: SBA.
No Attorney-Client F, ESnethen, Joe
Rojas, Maureen
Bryant, Stacey
Foster, Chuck
Nicholls, Mark
Shaw, Don
Arbolida, Max
Adair, Jerry*
O'Connor, Collen
Snethen, Joe
Chapman, Craig
Donovan, Tom
O'Keefe, Mary Lou
Payne, Jean
Wigle, James*
Goulet, Tom
Hultquist, Kyle
Sabol, Joy
Mercer, Peter
177 11/27/2000 Email providing analysis re: benefit calculations prepared at the request of counsel for purpose of providing legal advice and strategy in support of defense of ADEA claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Detrollo, N. O'Neill, Harry*
Gangone, Marie*
178 7/6/2001 Redacted communications from counsel reflecting legal advice provided in anticipation of litigation re: ADEA claim settlement.
HW0055100 HW0055102 Yes Attorney-Client; N/AWork Product
Rosenbaum, David* Gangone, Marie*
Covert, Kevin*
179 7/6/2001 Redacted communications from counsel reflecting legal advice provided in anticipation of litigation re: ADEA claim settlement.
HW0055097 HW0055099 Yes Attorney-Client; N/AWork Product
Rosenbaum, David* Gangone, Marie*
Covert, Kevin*
180 7/6/2001 Redacted communications from counsel reflecting legal advice provided in anticipation of litigation re: ADEA claim settlement.
HW0055094 HW0055096 Yes Attorney-Client; N/AWork Product
Rosenbaum, David* Gangone, Marie*
Covert, Kevin*
181 7/10/2001 Email providing information at the request of counsel re: ADEA settlement claim for purposes of providing legal advice in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; N/AWork Product
Vitale, Suzanne Gangone, Marie*
Covert, Kevin*
Page 26 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 27 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 182 9/13/2001 Email chain and attachment containing attorney-client
communications and providing legal advice re: draft communication to SBA participants.
No Attorney-Client F, EAcquaviva, Theresa Chapman, Craig Mathis, Kathleen
Kitchell, Carol
Payne, Jean
Saperstein, Steven
183 9/13/2001 Email chain and attachment containing attorney-client communications and providing legal advice re: draft communication to SBA participants.
No Attorney-Client F, EChapman, Craig Rojas, Maureen
Payne, Jean
Clarke, Allen*
184 10/2/2001 Email and attachment containing attorney-client communications re: potential SBA lawsuit.
No Attorney-Client F, EChapman, Craig Marcotte, Brian
Mathis, Kathleen
Payne, Jean
Yamasaki, Steve
Clarke, Allen*
Rojas, Maureen
185 10/2/2001 Email and attachment containing attorney-client communications re: potential SBA lawsuit.
No Attorney-Client F, EChapman, Craig Marcotte, Brian
Mathis, Kathleen
Payne, Jean
Yamasaki, Steve
Clarke, Allen*
Rojas, Maureen
186 10/4/2001 Email from counsel requesting information re: potential litigation by SBA participants for purposes of providing legal advice in anticipation of litigation and forwarding documents re: same.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Gangone, Marie*
187 5/1/2002 Handwritten notes reflecting legal analysis and prepared in anticipation of litigation re: benefit calculations.
No Attorney-Client; F, L, RWork Product
Mathis, Kathleen
Page 27 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 28 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 188 7/31/2002 Email seeking legal advice re: Department of Labor
inquiry re: SBA offset.No Attorney-Client F, EO'Neill, Harry* Burnelko, Cindy
Kitchell, Carol
Marcotte, Brian
Mathis, Kathleen
Racka, Walter
189 8/1/2002 Spreadsheet containing information prepared at the request of counsel and prepared in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, O, R, LWork Product
Hewitt Associates
190 8/1/2002 Spreadsheet containing information prepared at the request of counsel and prepared in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, O, R, LWork Product
Hewitt Associates
191 8/1/2002 Spreadsheet containing information prepared at the request of counsel and prepared in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, O, R, LWork Product
Hewitt Associates
192 8/1/2002 Spreadsheet containing information prepared at the request of counsel and prepared in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, O, R, LWork Product
Hewitt Associates
193 8/12/2002 Fax transmitting document to counsel re: administrative claims for purposes of providing legal advice in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Vine, John*
194 8/12/2002 Fax transmitting document to counsel re: administrative claims for purposes of providing legal advice in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Vine, John*
195 8/12/2002 Fax transmitting document to counsel re: administrative claims for purposes of providing legal advice in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Vine, John*
196 8/12/2002 Fax transmitting document to counsel re: administrative claims for purposes of providing legal advice in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Vine, John*
Page 28 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 29 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 197 8/13/2002 Email chain seeking information at the request of
counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, E, L, RWork Product
Gangone, Marie* Mathis, Kathleen
McDonald, Cathy
Bailey, Sandra
Williams, Sandy
Payne, Jean
Burnelko, Cindy
198 8/22/2002 Memo drafted by counsel in anticipation of litigation for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John*
199 8/22/2002 Memo drafted by counsel in anticipation of litigation for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John*
200 8/22/2002 Memo drafted by counsel in anticipation of litigation for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John*
201 9/3/2002 Notes and correspondence compiled by counsel for purposes of providing legal advice in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John*
202 9/5/2002 Email chain containing attorney-client communications and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* Huvelle, Jeffrey*
Shea, Richard*
203 9/10/2002 Email seeking information in furtherance of representation and for purposes of providing legal advice and strategy in anticipation of litigation and containing mental impressions of counsel re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* O'Neill, Harry* Huvelle, Jeffrey*
Shea, Richard*
204 9/10/2002 Spreadsheet containing information prepared at the request of counsel and prepared in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, O, R, LWork Product
Hewitt Associates
205 9/10/2002 Email chain containing attorney-client communications and reflecting mental impressions of counsel made in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* Shea, Richard*
Huvelle, Jeffrey*
Page 29 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 30 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 206 9/10/2002 Email chain containing attorney-client communications
and reflecting mental impressions of counsel made in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* O'Neill, Harry* Huvelle, Jeffrey*
Shea, Richard*
207 9/10/2002 Email from counsel providing legal advice and strategy in anticipation of litigation re: preparations for discussions with claimants' counsel re: SBA claims and forwarding correspondence re: same.
No Attorney-Client; F, E, LWork Product
O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Williams, Sandy
Covert, Kevin*
Greenman, Jane*
208 9/11/2002 Email from outside counsel requesting information re: administrative claims for purposes of providing legal counsel and strategy in anticipation of litigation.
No Attorney-Client; F, LWork Product
Vine, John* O'Neill, Harry* Huvelle, Jeffrey*
Shea, Richard*
209 9/11/2002 Email chain reflecting legal strategy and containing counsel's requests for information in anticipation of litigation and for the purpose of providing legal advice re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* O'Neill, Harry* Huvelle, Jeffrey*
Shea, Richard*
210 9/11/2002 Email containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John* O'Neill, Harry* Huvelle, Jeffrey*
Shea, Richard*
211 9/12/2002 Email containing legal analysis and requests of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, E, LWork Product
Gangone, Marie* Payne, Jean
Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Williams, Sandy
212 9/12/2002 Memo from counsel providing legal advice and legal strategy in anticipation of litigation re: potential legal defenses.
No Attorney-Client; F, LWork Product
Sonnenshein, Eric* Huvelle, Jeffrey*
Shea, Richard*
Vine, John*
213 9/12/2002 Memo from counsel providing legal advice and legal strategy in anticipation of litigation re: potential legal defenses.
No Attorney-Client; F, LWork Product
Sonnenshein, Eric* Huvelle, Jeffrey*
Shea, Richard*
Vine, John*
Page 30 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 31 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 214 9/12/2002 Memo from counsel providing legal advice and legal
strategy in anticipation of litigation re: potential legal defenses.
No Attorney-Client; F, LWork Product
Sonnenshein, Eric* Huvelle, Jeffrey*
Shea, Richard*
Vine, John*
215 9/12/2002 Memo from counsel providing legal advice and legal strategy in anticipation of litigation re: potential legal defenses.
No Attorney-Client; F, LWork Product
Sonnenshein, Eric* Huvelle, Jeffrey*
Shea, Richard*
Vine, John*
216 9/12/2002 Fax and attachment seeking information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, E, LWork Product
Gangone, Marie* Payne, Jean
217 9/13/2002 Email responding to instructions from counsel providing legal advice and strategy in anticipation of litigation re: preparations for discussions with claimants' counsel re: SBA claims and forwarding correspondence re: same.
No Attorney-Client; F, O, E, LWork Product
Mathis, Kathleen Denlinger, Kurt Gangone, Marie*
Burden, Jay
Mathis, Kathleen
Williams, Sandy
Payne, Jean
Vine, John*
218 9/13/2002 Handwritten notes reflecting mental impressions of counsel and legal strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, R, LWork Product
Mathis, Kathleen
219 9/13/2002 Email responding to instructions from counsel providing legal advice and strategy in anticipation of litigation re: preparations for discussions with claimants' counsel re: SBA claims and forwarding correspondence re: same.
No Attorney-Client; F, O, E, LWork Product
Mathis, Kathleen Denlinger, Kurt Gangone, Marie*
Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Williams, Sandy
Payne, Jean
Vine, John*
220 9/16/2002 Letter providing information at the request of counsel for purposes of obtaining legal advice and strategy in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Gangone, Marie* Vine, John*
Page 31 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 32 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 221 9/16/2002 Email transmitting attachment prepared at the request
of counsel and in anticipation of litigation re: claimant information.
No Attorney-Client; F, O, E, LWork Product
Denlinger, Kurt O'Neill, Harry* Conte, Carol
Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Payne, Jean
Williams, Sandy
Vine, John*
Shea, Richard*
222 9/16/2002 Email providing information at the request of counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation.
No Attorney-Client; F, O, E, U, LWork Product
Denlinger, Kurt O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Payne, Jean
Rigby, Barb
Hewitt Associates
223 9/16/2002 Email reflecting legal advice and strategy prepared in anticipation of litigation and summarizing attorney-client communication re: status of administrative claims.
No Attorney-Client; F, R, LWork Product
Holic, Mike Fagenson, Leslie
224 9/16/2002 Email containing attorney-client communications and attaching claimant information prepared at the request of counsel and in anticipation of litigation.
No Attorney-Client; F, O, E, U, LWork Product
Denlinger, Kurt O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Payne, Jean
Williams, Sandy
Vine, John*
Shea, Richard*
Conte, Carol
Page 32 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 33 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 225 9/18/2002 Memo containing attorney-client communications
prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, E, LWork Product
O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Payne, Jean
Williams, Sandy
226 9/25/2002 Email from counsel requesting information re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
227 9/25/2002 Email reflecting legal strategy and summarizing mental impressions of counsel and ongoing projects prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, E, LWork Product
O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Burnelko, Cindy
Payne, Jean
Williams, Sandy
Denlinger, Kurt
228 9/25/2002 Email reflecting legal strategy and containing requests for information from counsel re: administrative claims.
No Attorney-Client; F, O, E, LWork Product
O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Payne, Jean
Williams, Sandy
Denlinger, Kurt
229 9/26/2002 Email reflecting legal strategy and providing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, E, LWork Product
Denlinger, Kurt O'Neill, Harry* Burnelko, Cindy
Payne, Jean
Mathis, Kathleen
Gangone, Marie*
Williams, Sandy
Page 33 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 34 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 230 9/26/2002 Email responding to request for information from
counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, E, O, L, RWork Product
Denlinger, Kurt O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Payne, Jean
Rigby, Barb
Hewitt Associates
Client Records Distribution Mailbox@Hewitt Associates NA
231 9/26/2002 Email responding to request for information from counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, L, RWork Product
Mathis, Kathleen Denlinger, Kurt
O'Neill, Harry*
232 9/26/2002 Email reflecting legal strategy and providing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, E, L, R Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Payne, Jean
Williams, Sandy
233 9/26/2002 Email reflecting legal strategy and providing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, E, L, RWork Product
O'Neill, Harry* Denlinger, Kurt Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Payne, Jean
Williams, Sandy
Page 34 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 35 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 234 9/26/2002 Email reflecting legal strategy and providing information
prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, E, L, R Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Payne, Jean
Williams, Sandy
235 9/26/2002 Email responding to request for information from counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, E, L, RWork Product
Denlinger, Kurt O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Rigby, Barb
236 9/30/2002 Email chain containing attorney-client communications and reflecting information collected at the request of counsel in anticipation of litigation re: calculation of benefits for SBA participants.
No Attorney-Client; F, O, E, L, RWork Product
Denlinger, Kurt Burnelko, Cindy O'Neill, Harry*
Holic, Mike
Williams, Sandy
237 10/4/2002 Email from counsel re: information requested re: SBA claimants for purposes of providing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, O, L, RWork Product
Shea, Richard* Denlinger, Kurt
238 10/9/2002 Email responding to further request for information from counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, E, LWork Product
Payne, Jean O'Neill, Harry*
Mathis, Kathleen
Gangone, Marie*
Holic, Mike
239 10/9/2002 Email from counsel requesting additional information re: administrative claims for purpose of providing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
240 10/9/2002 Email chain reflecting legal strategy and containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Burnelko, Cindy
Page 35 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 36 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 241 10/9/2002 Email chain containing mental impressions of counsel
and requests for information from counsel prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, E, O, LWork Product
O'Neill, Harry* Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Payne, Jean
Williams, Sandy
Denlinger, Kurt
242 10/9/2002 Email reflecting legal strategy and summarizing mental impressions of counsel and ongoing projects prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, E, O, LWork Product
Payne, Jean O'Neill, Harry*
Mathis, Kathleen
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Williams, Sandy
Denlinger, Kurt
243 10/9/2002 Draft presentation reflecting legal advice and prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client, F, LWork Product
Covington & Burling*
244 10/10/2002 Email reflecting legal strategy and summarizing mental impressions of counsel and ongoing projects prepared at counsel's request in anticipation of litigation re: SBA claims.
No Attorney-Client; F, E, O, LWork Product
Williams, Sandy Mathis, Kathleen
Payne, Jean
O'Neill, Harry*
Gangone, Marie*
Holic, Mike
Burnelko, Cindy
Denlinger, Kurt
245 10/10/2002 Email responding to further request for information from counsel re: administrative claimants for purposes of securing legal advice and legal strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, E, LWork Product
Williams, Sandy Payne, Jean
O'Neill, Harry*
Mathis, Kathleen
Gangone, Marie*
Page 36 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 37 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 246 11/1/2002 Letter transmitting information and documents to
counsel re: SBA claims for purposes of securing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, L, RWork Product
Gangone, Marie* Vine, John* O'Neill, Harry*
Covert, Kevin*
247 11/1/2002 Letter transmitting information and documents to counsel re: SBA claims for purposes of securing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, L, RWork Product
Gangone, Marie* Vine, John* Covert, Kevin*
O'Neill, Harry*
248 11/6/2002 Email from counsel requesting additional information re: administrative claims for purpose of providing legal advice and strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Kitchell, Carol
D'Ariano, Frank
Denlinger, Kurt
Gangone, Marie*
249 11/6/2002 Email chain containing attorney-client communications and attorney requests made in anticipation of litigation re: SBA claimant information.
No Attorney-Client; F, O, E, LWork Product
D'Ariano, Frank Burnelko, Cindy Holic, Mike
Mathis, Kathleen
Gangone, Marie*
Payne, Jean
Williams, Sandy
Vine, John*
Shea, Richard*
Conte, Carol
250 11/6/2002 Email responding to requests for information from outside counsel re: SBA claims for purposes of obtaining legal advice and strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, LWork Product
D'Ariano, Frank Burnelko, Cindy O'Neill, Harry*
Kitchell, Carol
Denlinger, Kurt
Gangone, Marie*
251 11/6/2002 Email from counsel forwarding requests for information from outside counsel re: SBA claims for purposes of providing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Burnelko, Cindy
Holic, Mike
Kitchell, Carol
D'Ariano, Frank
Denlinger, Kurt
Gangone, Marie*
252 11/7/2002 Email chain containing attorney-client communications and information prepared at the request of counsel and in anticipation of litigation re: potential SBA claimants.
No Attorney-Client; F, O, E, U, L, RWork Product
Lopez, Al Studley, Jeanine Burnelko, Cindy
253 11/7/2002 Email chain containing attorney-client communications and information prepared at the request of counsel prepared and in anticipation of litigation re: potential claimant information.
No Attorney-Client; F, E, U, L, RWork Product
Lopez, Al Studley, Jeanine Burnelko, Cindy
Page 37 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 38 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 254 11/7/2002 Email chain containing attorney-client communications
and transmitting information prepared at the request of counsel and in anticipation of litigation re: SBA claimant information.
No Attorney-Client; F, E, U. L, RWork Product
Studley, Jeanine Lopez, Al Burnelko, Cindy
255 11/18/2002 Email responding to requests for information from outside counsel re: SBA claims for purposes of obtaining legal advice and strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, LWork Product
Burnelko, Cindy O'Neill, Harry*
Holic, Mike
Kitchell, Carol
D'Ariano, Frank
Gangone, Marie*
256 11/22/2002 Email responding to requests for information from outside counsel re: SBA claims for purposes of obtaining legal advice and strategy in anticipation of litigation and forwarding correspondence re: same.
No Attorney-Client; F, O, LWork Product
Conte, Carol Burnelko, Cindy O'Neill, Harry*
Denlinger, Kurt
257 12/23/2002 Email chain and attachment providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, E, L, DWork Product
Zbesko, Donna Burnelko, Cindy
258 1/8/2003 Fax containing attorney-client communications and mental impressions of counsel and transmitting correspondence in anticipation of litigation re: SBA claimants.
No Attorney-Client; F, LWork Product
Gangone, Marie* Vine, John*
259 1/10/2003 Memo and enclosure containing attorney-client communications sent at the request of counsel in anticipation of litigation re: SBA plan document.
No Attorney-Client F, LGangone, Marie* Shea, Richard*
260 1/16/2003 Draft letter reflecting legal advice and prepared in anticipation of litigation re: proposed response to administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
261 1/16/2003 Draft letter containing legal advice and mental impressions of counsel re: response to administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
262 1/24/2003 Draft letter reflecting legal advice and mental impressions of counsel re: response to administrative claims.
No Attorney-Client; N/AWork Product
Covington & Burling*
263 1/24/2003 Excerpt from draft letter containing legal advice and mental impressions of counsel re: response to administrative claims.
No Attorney-Client; N/AWork Product
Covington & Burling*
Page 38 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 39 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure 264 1/24/2003 Draft letter reflecting legal advice and mental
impressions of counsel re: response to administrative claims.
No Attorney-Client; N/AWork Product
Covington & Burling*
265 1/27/2003 Email chain seeking legal advice in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Shea, Richard* O'Neill, Harry*
Mathis, Kathleen
Greenman, Jane*
Denlinger, Kurt
Abraham, Ivy*
Sandstrom, Gus*
266 1/27/2003 Email chain seeking information at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Conte, Carol Ross, Doug Denlinger, Kurt
267 1/28/2003 Handwritten notes containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Abraham, Ivy*
O'Neill, Harry*
O'Neill, Harry*
Greenman, Jane*
Mathis, Kathleen
Denlinger, Kurt
Vine, John*
Shea, Richard*
268 1/30/2003 Handwritten notes reflecting legal advice and analysis prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Mathis, Kathleen
269 1/31/2003 Email chain containing attorney-client communications and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Greenman, Jane*
Mathis, Kathleen
Denlinger, Kurt
270 1/31/2003 Email containing attorney-client communications and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Greenman, Jane*
Mathis, Kathleen
Denlinger, Kurt
271 2/1/2003 Presentation prepared at the request of counsel and in anticipation of litigation containing handwritten notes reflecting mental impressions of counsel re: SBA offset.
No Attorney-Client; N/AWork Product
O'Neill, Harry*
272 2/1/2003 Presentation prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; N/AWork Product
Hewitt Associates
Page 39 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 40 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure273 2/1/2003 Presentation prepared at the request of counsel and in
anticipation of litigation containing handwritten notes reflecting mental impressions of counsel re: SBA offset.
No Attorney-Client; N/A Work Product
O'Neill, Harry*
274 2/1/2003 Charts with handwritten notes reflecting legal advice and containing analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Covington & Burling*
275 2/1/2033 Presentation prepared at the request of counsel and in anticipation of litigation re: analysis of merger of Garrett and Signal retirement plans.
No Attorney-Client; N/AWork Product
O'Neill, Harry*
276 2/1/2003 Presentation prepared at the request of counsel and in anticipation of litigation re: 2000 amendments to Honeywell retirement plan.
No Attorney-Client; N/AWork Product
Hewitt Associates
277 2/1/2003 Presentation prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; N/AWork Product
Hewitt Associates
278 2/1/2003 Charts prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; N/A Work Product
Hewitt Associates
279 2/1/2003 Document containing information prepared at the request of counsel and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
Hewitt Associates
280 2/1/2003 Presentation with handwritten notes prepared at the request of counsel and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; N/AWork Product
Covington & Burling*
281 2/3/2003 Email chain and attachment containing information prepared at the request of counsel and in anticipation of litigation and mental impressions of counsel re: SBA offset.
No Attorney-Client; N/A Work Product
O'Neill, Harry*
Denlinger, Kurt
Gangone, Marie
O'Neill, Harry*
Greenman, Jane*
Mathis, Kathleen
Ross, Doug
Shea, Richard*
Vine, John*
Page 40 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 41 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure282 2/3/2003 Email containing information prepared at the request of
counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Vine, John*
Shea, Richard*
Greenman, Jane*
Ross, Doug
Rigby, Barb
283 2/3/2003 Email chain containing mental impressions of counsel and legal analysis prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt
O'Neill, Harry*
Mathis, Kathleen
Vine, John*
Sandstrom, Gus*
Greenman, Jane*
Ross, Doug
284 2/3/2003 Memo containing legal analysis and strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Sandstrom, Gus* Shea, Richard*
Vine, John*
285 2/3/2003 Memo containing legal analysis and strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Sandstrom, Gus* Shea, Richard*
Vine, John*
286 2/3/2003 Email with handwritten notes containing legal analysis and information prepared at the request of counsel in anticipation of litigation re: benefits calculation.
No Attorney-Client; N/A Work Product
Shea, Richard*
Mathis, Kathleen
Denlinger, Kurt
O'Neill, Harry*
Mathis, Kathleen
Vine, John*
Greenman, Jane*
Ross, Doug
Sandstrom, Gus*
287 2/3/2003 Email containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Vine, John*
Shea, Richard*
Greenman, Jane*
Ross, Doug
288 2/3/2003 Email chain seeking information at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Conte, Carol Ross, Doug Denlinger, Kurt
Page 41 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 42 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure289 2/3/2003 Email chain providing legal analysis and mental
impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt
O'Neill, Harry*
Mathis, Kathleen
Vine, John*
Greenman, Jane*
Ross, Doug
290 2/4/2003 Email transmitting legal analysis and other information prepared by and at the request of counsel in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Mathis, Kathleen Burnelko, Cindy
291 2/4/2003 Email chain and attachment transmitting legal analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Burnelko, Cindy
292 2/4/2003 Email chain and attachment transmitting legal analysis and other information prepared by and at the request of counsel in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Burnelko, Cindy
293 2/5/2003 Email chain seeking legal advice in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
O'Neill, Harry*
Ross, Doug
294 2/5/2003 Email chain seeking information at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Conte, Carol Ross, Doug Denlinger, Kurt
295 2/5/2003 Email chain containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
O'Neill, Harry*
Ross, Doug
296 2/6/2003 Email chain providing legal advice, analysis, and strategy in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt Sandstrom, Gus*
O'Neill, Harry*
Ross, Doug
297 2/7/2003 Email chain providing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
O'Neill, Harry*
Rigby, Barb
Page 42 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 43 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure298 2/7/2003 Email chain containing legal analysis and information
prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
O'Neill, Harry*
Burnelko, Cindy
299 2/7/2003 Email chain containing legal analysis and information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
O'Neill, Harry*
Burnelko, Cindy
Mathis, Kathleen
300 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Abbate, Tony O'Neill, Harry*
301 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Abbate, Tony O'Neill, Harry*
302 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Abbate, Tony O'Neill, Harry*
303 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Abbate, Tony O'Neill, Harry*
304 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Abbate, Tony O'Neill, Harry*
305 2/10/2003 Email containing attorney-client communications and reflecting legal strategy prepared in anticipation of litigation re: conference with claimants' attorney.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Shea, Richard*
Denlinger, Kurt
Mathis, Kathleen
Gangone, Marie*
306 2/10/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Abbate, Tony O'Neill, Harry*
307 2/11/2003 Email chain containing legal strategy and attorney-client communications re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Shea, Richard*
Denlinger, Kurt
Page 43 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 44 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure308 2/12/2003 Email providing legal analysis and mental impressions
of counsel and seeking information prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt O'Neill, Harry*
Sandstrom, Gus*
309 2/14/2003 Email providing information prepared at the request of counsel and in anticipation of litigation re: calculation of benefits under Garrett Retirement Plan.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Sandstrom, Gus* Shea, Richard*
Mathis, Kathleen
O'Neill, Harry*
310 2/14/2003 Email chain providing analysis prepared at the request of counsel and in anticipation of litigation re: calculation of benefits under Garrett Retirement Plan.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Sandstrom, Gus* Shea, Richard*
Mathis, Kathleen
O'Neill, Harry*
311 2/21/2003 Handwritten notes reflecting legal analysis re: benefit calculations prepared in anticipation of litigation.
No Attorney-Client; N/AWork Product
Mathis, Kathleen
312 2/24/2003 Email chain requesting analysis in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt O'Neill, Harry*
Sandstrom, Gus*
313 2/24/2003 Email requesting analysis in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Denlinger, Kurt
314 2/24/2003 Email providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: presentation to claimants' counsel.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Ross, Doug
Gangone, Marie*
Burnelko, Cindy
315 2/24/2003 Email reflecting legal analysis and containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
O'Neill, Harry*
Burnelko, Cindy
Mathis, Kathleen
Gangone, Marie*
Page 44 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 45 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure316 2/24/2003 Email providing information prepared at the request of
counsel, in furtherance of representation, and in anticipation of litigation re: presentation to claimants' counsel.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Ross, Doug
Rigby, Barb
317 2/24/2003 Email reflecting legal analysis and containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Gangone, Marie*
Burnelko, Cindy
318 2/25/2003 Email chain providing information requested by counsel in anticipation of litigation re: individual claimants.
No Attorney-Client; N/AWork Product
Williams, Sandy Conte, Carol Denlinger, Kurt
319 2/26/2003 Email chain re: information prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: draft presentation re: SBA.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Gangone, Marie*
320 2/26/2003 Email providing information requested by counsel in furtherance of representation and in anticipation of litigation re: SBA benefits calculations.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Ross, Doug
Rigby, Barb
321 2/26/2003 Email providing information requested by counsel and in anticipation of litigation re: SBA benefits calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
322 2/26/2003 Email containing information prepared at the request of counsel and in anticipation of litigation re: benefit calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Page 45 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 46 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure323 2/26/2003 Email containing information prepared at the request of
counsel and in anticipation of litigation re: benefit calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
324 2/27/2003 Email chain containing legal strategy and mental impressions of counsel formulated in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Vine, John*
Shea, Richard*
Denlinger, Kurt
325 2/27/2003 Email chain containing legal strategy formulated in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Vine, John*
Shea, Richard*
Denlinger, Kurt
Mathis, Kathleen
Greenman, Jane*
Burnelko, Cindy
Gangone, Marie*
326 3/2/2003 Email providing information requested by counsel and in anticipation of litigation re: SBA benefits calculations.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
Ross, Doug
Rigby, Barb
327 3/2/2003 Email with handwritten notes containing attorney-client communication and information prepared at the request of counsel and in anticipation of litigation re: SBA benefit calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt
Mathis, Kathleen
Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
328 3/2/2003 Email chain providing information requested by counsel in furtherance of representation and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Gangone, Marie* Burnelko, Cindy
Ross, Doug
Mathis, Kathleen
Page 46 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 47 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure329 3/2/2003 Email providing information requested by counsel in
furtherance of representation and in anticipation of litigation re: SBA benefits calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
330 3/2/2003 Email chain and attachment transmitting information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Gangone, Marie* Burnelko, Cindy
Ross, Doug
Mathis, Kathleen
O'Neill, Harry*
331 3/2/2003 Email containing analysis prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: calculation of SBA benefits.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
332 3/2/2003 Email containing information prepared at the request of counsel and in anticipation of litigation re: operation of SBA offset.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Sandstrom, Gus*
Mathis, Kathleen
O'Neill, Harry*
333 3/5/2003 Draft presentation with handwritten notes containing the mental impressions of counsel formulated in anticipation of litigation re: merger of Garrett and Signal retirement plans.
No Attorney-Client; N/AWork Product
O'Neill, Harry*
334 3/5/2003 Email containing information prepared at the request of counsel and in anticipation of litigation re: SBA plan changes.
No Attorney-Client; N/AWork Product
Mathis, Kathleen O'Neill, Harry*
Greenman, Jane*
Denlinger, Kurt
335 3/5/2003 Presentation with handwritten notes reflecting legal advice and containing information prepared at the request of counsel and in anticipation of litigation re: merger of Garrett and Signal retirement plans.
No Attorney-Client; N/A Work Product
Mathis, Kathleen
336 3/5/2003 Document with handwritten notes prepared at the request of counsel and in anticipation of litigation and containing mental impressions of counsel re: SBA plan.
No Attorney-Client; N/AWork Product
Covington & Burling*
337 3/5/2003 Document prepared at the request of counsel and in anticipation of litigation and containing mental impressions of counsel re: SBA plan.
No Attorney-Client; N/A Work Product
Hewitt Associates
338 3/5/2003 Draft document prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; N/AWork Product
Hewitt Associates
Page 47 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 48 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure339 3/5/2003 Draft document prepared at the request of counsel in
furtherance of representation and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; N/AWork Product
Hewitt Associates
340 3/6/2003 Email chain containing information provided at the request of counsel and in anticipation of litigation and mental impressions of counsel re: 2000 Signal Plan.
No Attorney-Client; N/A Work Product
Greenman, Jane* Mathis, Kathleen
O'Neill, Harry*
Denlinger, Kurt
341 3/10/2003 Email chain providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Ross, Doug Abbate, Tony Denlinger, Kurt
342 3/12/2003 Email chain providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Ross, Doug Abbate, Tony Denlinger, Kurt
343 3/12/2003 Email chain providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Ross, Doug Abbate, Tony Denlinger, Kurt
344 3/12/2003 Email chain providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Ross, Doug Abbate, Tony Denlinger, Kurt
345 3/31/2003 Email chain providing information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Ross, Doug Denlinger, Kurt
346 4/25/2003 Fax and attachment containing mental impressions of counsel and legal advice prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Vine, John* O'Neill, Harry*
347 5/2/2003 Email chain containing legal advice and strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Shea, Richard* Mathis, Kathleen
Denlinger, Kurt
Huvelle, Jeffrey*
Vine, John*
348 5/6/2003 Email chain containing mental impressions of counsel and attorney-client communications re: meeting with claimants' counsel.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Greenman, Jane*
Mathis, Kathleen
Gangone, Marie*
Burnelko, Cindy
Page 48 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 49 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure349 5/23/2003 Email and handwritten notes containing mental
impressions of counsel and legal strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Covert, Kevin*
Burnelko, Cindy
Mathis, Kathleen
Gangone, Marie*
Vine, John*
Shea, Richard*
Denlinger, Kurt
Orella, Laura
350 5/27/2003 Email chain seeking information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Ross, Doug Denlinger, Kurt Burnelko, Cindy
Galdi, L.
Martini, Mike
Gangone, Marie*
351 5/30/2003 Email containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry*
Shea, Richard*
Mathis, Kathleen
352 5/30/2003 Email seeking legal advice and strategy and containing analysis prepared at the request of counsel in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt
Shea, Richard*
Mathis, Kathleen
353 5/30/2003 Email providing analysis requested by counsel in furtherance of representation and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/A Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Rigby, Barb
354 5/30/2003 Email providing analysis requested by counsel in furtherance of representation and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry*
Shea, Richard*
Mathis, Kathleen
355 5/30/2003 Email containing attorney-client communications and reflecting legal strategy prepared in anticipation of litigation re: individual SBA benefit calculations.
No Attorney-Client; N/A Work Product
Denlinger, Kurt O'Neill, Harry* Mathis, Kathleen
Shea, Richard*
356 6/2/2003 Email chain containing legal strategy and mental impressions of counsel made in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt
357 6/4/2003 Email from counsel requesting documents and information re: plan documents for purposes of providing legal advice and strategy in anticipation of litigation.
No Attorney-Client; N/A Work Product
Shea, Richard* Gordon, David* O'Neill, Harry*
Page 49 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 50 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure358 6/4/2003 Email providing analysis requested by counsel in
furtherance of representation and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
359 6/4/2003 Email providing analysis requested by counsel in furtherance of representation and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
360 6/4/2003 Email providing legal strategy and mental impressions of counsel in anticipation of litigation re: exhibit to Garrett Retirement Plan.
No Attorney-Client; N/A Work Product
Shea, Richard* O'Neill, Harry* Denlinger, Kurt
Sandstrom, Gus*
361 6/4/2003 Email providing analysis requested by counsel in furtherance of representation and in anticipation of litigation re: individual benefit calculation.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
362 6/6/2003 Draft memo reflecting legal strategy and containing mental impressions of counsel prepared in furtherance of representation and in anticipation of litigation re: analysis of anti-cutback rule.
No Attorney-Client; N/A Work Product
Sandstrom, Gus*
363 6/6/2003 Draft memo reflecting legal strategy and containing mental impressions of counsel prepared in furtherance of representation and in anticipation of litigation re: analysis of anti-cutback rule.
No Attorney-Client; N/A Work Product
Sandstrom, Gus*
364 6/6/2003 Draft memo reflecting legal strategy and containing mental impressions of counsel prepared in furtherance of representation and in anticipation of litigation re: analysis of anti-cutback rule.
No Attorney-Client; N/AWork Product
Sandstrom, Gus*
365 6/9/2003 Memo containing legal analysis and mental impressions of counsel and prepared in anticipation of litigation re: fiduciary exception to attorney-client privilege.
No Attorney-Client; N/AWork Product
Sonnenshein, Eric* Huvelle, Jeffrey*
366 6/9/2003 Email chain containing attorney-client communications and information prepared at the request of counsel, in furtherance of representation, and in anticipation of litigation re: sampling of individual benefits calculations.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Burnelko, Cindy O'Neill, Harry*
367 6/9/2003 Email and attachment transmitting information prepared at the request of counsel and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/A Work Product
Nanovic, Cathy Burnelko, Cindy Racka, Debbie
Page 50 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 51 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure368 6/9/2003 Memo containing legal analysis and mental
impressions of counsel prepared in anticipation of litigation re: fiduciary exception to attorney-client privilege.
No Attorney-Client; N/A Work Product
Sonnenshein, Eric* Huvelle, Jeffrey*
369 6/9/2003 Email transmitting information prepared at the request of counsel and in anticipation of litigation re: calculation of benefits under the Garrett plans.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Denlinger, Kurt Burnelko, Cindy
O'Neill, Harry*
370 6/9/2003 Email chain seeking information prepared at request of counsel, in furtherance of representation, and in anticipation of litigation re: SBA claimants.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Burnelko, Cindy O'Neill, Harry*
371 6/9/2003 Email chain providing information prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: sampling of individual benefits calculations.
No Attorney-Client; N/A Work Product
Denlinger, Kurt Denlinger, Kurt Burnelko, Cindy
O'Neill, Harry*
372 6/9/2003 Memo containing legal analysis and mental impressions of counsel prepared in anticipation of litigation re: fiduciary exception to attorney-client privilege.
No Attorney-Client; N/A Work Product
Sonnenshein, Eric* Huvelle, Jeffrey*
373 6/10/2003 Handwritten notes reflecting request for legal advice in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Mathis, Kathleen
374 6/11/2003 Email chain containing attorney-client communications requesting information in furtherance of representation and in anticipation of litigation re: filing of IRS determination letter.
No Attorney-Client; N/A Work Product
Vine, John* Gangone, Marie*
Shea, Richard*
375 7/1/2003 Document containing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; N/A Work Product
Covington & Burling*
376 7/1/2003 Document containing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; N/A Work Product
Covington & Burling*
377 7/9/2003 Email and attachment seeking information prepared at the request of counsel and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; F/L Work Product
Gangone, Marie* Burnelko, Cindy
Vine, John*
Shea, Richard*
Page 51 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 52 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure378 7/25/2003 Email containing legal advice and reflecting mental
impressions of counsel in anticipation of litigation re: response to appeal of denial of administrative claims.
No Attorney-Client; F, LWork Product
Shea, Richard* O'Neill, Harry* Huvelle, Jeffrey*
Vine, John*
Sandstrom, Gus*
379 8/2/2003 Document prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; F, O, U, L, RWork Product
Hewitt Associates
380 8/14/2003 Email and attachment prepared at the request of counsel seeking information in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; F, O, L Work Product
Gangone, Marie* Burnelko, Cindy
Denlinger, Kurt
381 8/14/2003 Email and attachment seeking information prepared at the request of counsel and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; F, O, L Work Product
Gangone, Marie* Burnelko, Cindy
Denlinger, Kurt
382 8/17/2003 Email containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: draft response to administrative claims.
No Attorney-Client; F, LWork Product
Ryan, James* Shea, Richard* Huvelle, Jeffrey*
383 9/22/2003 Email chain providing information prepared at the request of counsel in anticipation of litigation re: sample benefit calculation.
No Attorney-Client; F, O, LWork Product
Denlinger, Kurt O'Neill, Harry* Vine, John*
Shea, Richard*
384 9/22/2003 Fax conveying correspondence re: administrative claim for purpose of developing legal advice and strategy in anticipation of litigation.
No Attorney-Client; F, LWork Product
Ryan, James* Shea, Richard*
385 9/24/2003 Fax and attachment enclosing information used in furtherance of representation and in anticipation of litigation re: individual benefit file.
No Attorney-Client; F, LWork Product
Ryan, James* Shea, Richard*
386 9/25/2003 Email and attachment seeking information prepared at the request of counsel and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; F, O, LWork Product
Gangone, Marie* Burnelko, Cindy
Denlinger, Kurt
387 9/25/2003 Handwritten notes reflecting attorney-client communications and containing mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
388 9/29/2003 Memo and attachment transmitting information in furtherance of representation and in anticipation of litigation re: 1984 Signal Plan Amendments.
HW0055022 HW0055025 Yes Attorney-Client; F, L Work Product
Gangone, Marie* Shea, Richard*
Page 52 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 53 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure389 10/1/2003 Draft letter prepared in anticipation of litigation
containing mental impressions of counsel and legal analysis re: denial of administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
390 10/9/2003 Draft letter reflecting legal advice and prepared in anticipation of litigation re: proposed response appeal of denial of administrative claims.
No Attorney-Client; F, L, RWork Product
Marcotte, Brian
391 10/9/2003 Draft letter prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: denial of appeal of administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
392 10/9/2003 Draft letter prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: denial of appeal of administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
393 10/9/2003 Draft letter prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: denial of appeal of administrative claims.
No Attorney-Client; F, L Work Product
Covington & Burling*
394 10/9/2003 Email chain and attachment transmitting draft letter denying appeal of administrative claims prepared in anticipation of litigation.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Covert, Kevin*
Gangone, Marie*
Mathis, Kathleen
Burnelko, Cindy
Denlinger, Kurt
395 10/9/2003 Email chain and attachment transmitting draft letter denying plaintiffs' appeal of claim denial prepared by counsel in anticipation of litigation.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Covert, Kevin*
Gangone, Marie*
Mathis, Kathleen
Burnelko, Cindy
Denlinger, Kurt
396 10/9/2003 Chart with handwritten notes prepared in anticipation of litigation containing legal analysis and strategy re: administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
397 10/10/2003 Email chain prepared in anticipation of litigation containing attorney-client communications and mental impressions of counsel re: minimum benefit claim and SBA offset.
No Attorney-Client; F, O, LWork Product
Denlinger, Kurt O'Neill, Harry*
Page 53 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 54 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure398 10/10/2003 Draft letter with handwritten notes prepared in
anticipation of litigation containing mental impressions of counsel and legal analysis re: denial of appeal of administrative claims.
No Attorney-Client; F, L Work Product
Covington & Burling*
399 10/14/2003 Email chain prepared in anticipation of litigation containing attorney-client communications and mental impressions of counsel re: calculation of SBA benefits.
No Attorney-Client; F, O, LWork Product
Denlinger, Kurt Shea, Richard*
400 10/14/2003 Analysis reflecting legal advice, legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
401 10/17/2003 Email chain and attachment reflecting legal advice and transmitting information prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Mathis, Kathleen
402 10/17/2003 Email and attachment transmitting information prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: SBA offset.
No Attorney-Client; F, O, L, RWork Product
Denlinger, Kurt Mathis, Kathleen O'Neill, Harry*
Shea, Richard*
403 10/17/2003 Email chain and attachment transmitting information prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: SBA offset.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry* Mathis, Kathleen
404 10/20/2003 Draft letter with handwritten notes prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: appeal of denial of administrative claims.
No Attorney-Client; F,, LWork Product
Covington & Burling*
405 10/20/2003 Email providing legal analysis and containing information compiled at the request of counsel and in anticipation of litigation re: calculation of benefits under the Garrett plans.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Vine, John*
Shea, Richard*
Denlinger, Kurt
Mathis, Kathleen
Covert, Kevin*
Gangone, Marie*
Burnelko, Cindy
406 10/20/2003 Email providing legal analysis and containing information compiled at the request of counsel and in anticipation of litigation re: calculation of benefits under the Garrett plans.
No Attorney-Client; F, O, LWork Product
O'Neill, Harry* Vine, John*
Shea, Richard*
Denlinger, Kurt
Mathis, Kathleen
Covert, Kevin*
Gangone, Marie*
Burnelko, Cindy
Page 54 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 55 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure407 10/20/2003 Email and attachment transmitting legal advice and
draft letter denying appeal of denial of administrative claims prepared in anticipation of litigation.
No Attorney-Client; F, L Work Product
O'Neill, Harry* Marcotte, Brian
Mathis, Kathleen
Covert, Kevin*
Gangone, Marie*
408 10/22/2003 Email and attachment seeking information prepared at the request of counsel and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; F, O, LWork Product
Gangone, Marie* Burnelko, Cindy
Denlinger, Kurt
409 10/23/2003 Email and attachment transmitting legal analysis of administrative claims prepared in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Marcotte, Brian Covert, Kevin*
Mathis, Kathleen
Burnelko, Cindy
Gangone, Marie*
410 10/23/2003 Email chain and attachment containing legal analysis of administrative claims prepared in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Marcotte, Brian Covert, Kevin*
Mathis, Kathleen
Burnelko, Cindy
Gangone, Marie*
411 10/24/2003 Draft letter prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: appeal of denial of administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
412 10/27/2003 Fax transmitting document containing handwritten notes reflecting mental impressions of counsel and prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Ryan, James*
O'Neill, Harry*
O'Neill, Harry*
413 10/29/2003 Draft letter reflecting legal advice prepared in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
414 10/29/2003 Email chain and attachment providing legal advice and draft letter denying appeal of administrative claims prepared in anticipation of litigation.
No Attorney-Client; F, LWork Product
O'Neill, Harry* Mathis, Kathleen
415 10/29/2003 Draft letter prepared in anticipation of litigation containing mental impressions of counsel and legal analysis re: appeal of denial of administrative claims.
No Attorney-Client; F, LWork Product
O'Neill, Harry*
Page 55 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 56 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure416 10/29/2003 Draft letter containing legal analysis and prepared in
anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; F, LWork Product
Marcotte, Brian
417 10/30/2003 Email transmitting information prepared at the request of counsel and in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; N/AWork Product
Gangone, Marie* Denlinger, Kurt
418 10/30/2003 Email transmitting information prepared at the request of counsel and in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; N/AWork Product
Gangone, Marie* Denlinger, Kurt
419 10/31/2003 Email and attachment seeking information prepared at the request of counsel and in furtherance of representation and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; N/AWork Product
Gangone, Marie* Denlinger, Kurt
420 11/4/2003 Email chain reflecting legal strategy and including mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/A Work Product
Vine, John* Covert, Kevin*
O'Neill, Harry*
Shea, Richard*
421 11/4/2003 Email chain reflecting legal strategy and including mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt Covert, Kevin*
422 11/5/2003 Email chain reflecting legal strategy and including mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt
423 11/5/2003 Email transmitting counsel's request for information in furtherance of representation and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; N/AWork Product
Gangone, Marie* Abbate, Tony O'Neill, Harry*
Burnelko, Cindy
Denlinger, Kurt
424 11/6/2003 Email chain containing legal advice and requests for legal advice re: summary plan description re: SBA benefits.
No Attorney-Client N/ABurnelko, Cindy O'Neill, Harry*
Denlinger, Kurt
425 11/7/2003 Email and attachment reflecting legal strategy and mental impressions of counsel prepared in anticipation of litigation re: response to inquiry from claimants' counsel.
No Attorney-Client; N/AWork Product
Gangone, Marie* O'Neill, Harry*
Abbate, Tony
Burnelko, Cindy
Denlinger, Kurt
Page 56 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 57 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure426 11/7/2003 Email chain reflecting legal strategy and including
mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Shea, Richard* Vine, John*
Covert, Kevin*
O'Neill, Harry*
Denlinger, Kurt
427 11/7/2003 Email and attachment containing attorney-client communications and transmitting information prepared in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; N/AWork Product
Gangone, Marie* O'Neill, Harry*
Abbate, Tony
Burnelko, Cindy
Denlinger, Kurt
428 11/14/2003 Handwritten notes reflecting attorney-client communications prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Chapman, Craig
429 11/17/2003 Calendar entry containing handwritten notes reflecting mental impressions of counsel made in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry*
430 11/19/2003 Email chain seeking document in anticipation of litigation and reflecting attorney-client communications re: potential SBA lawsuit.
No Attorney-Client, N/AWork Product
Chapman, Craig Gangone, Marie* Payne, Jean
Rojas, Maureen
431 11/19/2003 Email chain reflecting legal advice and containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry* Covert, Kevin*
Potts, Kevin
Dodds, Michael
Rigby, Barb
Client Records Distribution Mailbox@Hewitt Associates NA
432 11/20/2003 Email chain reflecting legal advice and containing information prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Dodds, Michael Covert, Kevin*
Kelly, Robert
O'Neill, Harry*
Potts, Kevin
433 12/4/2003 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Hewitt Associates
Page 57 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 58 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure434 12/5/2003 Email chain summarizing analysis prepared at the
request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
Vine, John*
Covert, Kevin*
Ross, Doug
Rigby, Barb
Client Records Distribution Mailbox@Hewitt Associates NA
435 12/11/2003 Handwritten notes containing legal advice and strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Covington & Burling*
436 12/15/2003 Email summarizing analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
Vine, John*
Covert, Kevin*
Conte, Carol
Rigby, Barb
437 12/16/2003 Email chain summarizing analysis prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
Vine, John*
Covert, Kevin*
Conte, Carol
438 12/16/2003 Email chain containing analysis prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Conte, Carol
O'Neill, Harry*
Vine, John*
Client Records Distribution Mailbox@Hewitt Associates NARigby, Barb
Covert, Kevin*
Page 58 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 59 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure439 12/17/2003 Email chain summarizing analysis prepared at the
request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Vine, John*
Covert, Kevin*
O'Neill, Harry*
Conte, Carol
440 12/17/2003 Email from counsel forwarding analysis and providing legal advice and strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Shea, Richard* Denlinger, Kurt Vine, John*
Covert, Kevin*
O'Neill, Harry*
Conte, Carol
441 12/22/2003 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Hewitt Associates
442 12/22/2003 Email chain reflecting legal strategy and containing analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry*
Covert, Kevin*
Shea, Richard*
443 12/22/2003 Email from counsel forwarding analysis and providing legal advice and strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Vine, John*
Covert, Kevin*
O'Neill, Harry*
Conte, Carol
Ross, Doug
444 1/8/2004 Handwritten notes containing mental impressions of counsel and prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
O'Neill, Harry*
445 1/9/2004 Email describing analysis prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* Ross, Doug
Woodring, Wendy
Rigby, Barb
446 1/9/2004 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Hewitt Associates
447 1/12/2004 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Hewitt Associates
Page 59 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 60 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure448 1/12/2004 Email describing analysis prepared at the request of
counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt Shea, Richard* O'Neill, Harry*
Woodring, Wendy
Ross, Doug
Rigby, Barb
449 1/13/2004 Email containing mental impressions of counsel re: analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* Denlinger, Kurt O'Neill, Harry*
450 1/13/2004 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Hewitt Associates
451 1/15/2004 Email containing legal advice and mental impressions of counsel re: analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/A Work Product
Shea, Richard* O'Neill, Harry*
Covert, Kevin*
Huvelle, Jeffrey*
Denlinger, Kurt
452 1/15/2004 Email containing legal advice and mental impressions of counsel re: analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Shea, Richard* Covert, Kevin*
O'Neill, Harry*
Huvelle, Jeffrey*
Denlinger, Kurt
453 1/16/2004 Email from counsel forwarding legal advice and strategy in anticipation of litigation re: potential responses to claims and defenses.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt
454 1/16/2004 Email from counsel forwarding legal advice and strategy in anticipation of litigation re: potential responses to claims and defenses.
No Attorney-Client; N/AWork Product
O'Neill, Harry* Denlinger, Kurt
455 1/20/2004 Email requesting legal advice and strategy from counsel in anticipation of litigation re: potential responses to claims and defenses and forwarding correspondence re: same.
No Attorney-Client; N/AWork Product
Covert, Kevin* Shea, Richard*
O'Neill, Harry*
Vine, John*
Huvelle, Jeffrey*
Denlinger, Kurt
456 1/22/2004 Email and attachment seeking information at the request of counsel and in anticipation of litigation re: additional SBA claimants.
No Attorney-Client; N/AWork Product
Gangone, Marie* Burnelko, Cindy
Denlinger, Kurt
Page 60 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 61 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure457 2/7/2004 Email requesting legal advice and strategy from
counsel in anticipation of litigation re: potential responses to claims and defenses and forwarding correspondence re: same.
No Attorney-Client; N/AWork Product
Covert, Kevin* Shea, Richard*
O'Neill, Harry*
Denlinger, Kurt
458 2/7/2004 Email chain containing legal advice and mental impressions of counsel and counsel's request for analysis in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/A Work Product
O'Neill, Harry* Denlinger, Kurt
Covert, Kevin*
459 2/10/2004 Email summarizing analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry* Covert, Kevin*
Shea, Richard*
Ross, Doug
Woodring, Wendy
460 2/10/2004 Email containing information prepared at the request of counsel in furtherance of representation and in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry* Covert, Kevin*
Shea, Richard*
Ross, Doug
Woodring, Wendy
461 2/10/2004 Email summarizing analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry*
Covert, Kevin*
Shea, Richard*
Ross, Doug
Woodring, Wendy
462 2/21/2004 Email summarizing analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; N/AWork Product
Denlinger, Kurt O'Neill, Harry* Woodring, Wendy
Ross, Doug
463 2/26/2004 Email chain containing legal advice and mental impressions of counsel made in anticipation of litigation re: administrative claims.
No Attorney-Client; N/AWork Product
Covert, Kevin* Shea, Richard*
Covert, Kevin*
O'Neill, Harry*
Huvelle, Jeffrey*
Egan, Kimberly
Gongora, Katherine*
464 10/1/2005 Memo providing legal advice and analysis re: designation of fiduciaries in plan documents.
HW0031044 HW0031055 Yes Attorney-Client N/ACovert, Kevin*
Dooley, Lisa*
Cote, David
Page 61 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 62 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure465 10/2/2006 Cover sheet and attachment containing attorney-client
communications re: SBA offset and Social Security offset transmitted for purposes of litigation.
HW0031772 HW0031783 Yes Attorney-Client; N/AWork Product
Chapman, Craig Hayne, Azeez*
466 12/1/2006 Chart reflecting advice of counsel and containing information prepared at the request of counsel and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; N/AWork Product
Hewitt Associates
467 Chronology prepared by counsel in anticipation of litigation re: plan amendments for purposes of providing legal advice and strategy.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
468 Handwritten notes reflecting legal strategy and mental impressions of counsel re: administrative claims in anticipation of litigation.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
469 Plan documents bearing handwritten notes reflecting mental impressions of counsel and legal strategy prepared in anticipation of litigation re: Signal Retirement Plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
470 Memo prepared by counsel in anticipation of litigation providing legal advice and strategy re: administrative claims and potential defenses.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
471 Plan documents bearing handwritten notes reflecting mental impressions and legal strategy of counsel prepared in anticipation of litigation re: Garrett Retirement Plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
472 Plan documents bearing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: SBA offset.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
473 Plan documents bearing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: SBA offset.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
474 Plan documents bearing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: SBA offset.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
475 Presentation reflecting information assembled in furtherance of representation and in anticipation of litigation re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
Page 62 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 63 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure476 Summaries containing mental impressions of counsel
and legal strategy prepared in anticipation of litigation re: plan language.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
477 Notes reflecting legal analysis and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
478 Plan documents bearing handwritten notes providing legal advice and mental impressions of counsel re: plan document.
No Attorney-Client F, RDebevoise & Plimpton*
479 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
480 Redacted handwritten notes to counsel re: legal advice concerning plan documents and early retirement factors.
HW0055410 HW0055414 Yes Attorney-Client F, R,Rauch, Richard Debevoise & Plimpton*
481 Chart containing analysis prepared at the request of counsel for purposes of developing legal advice and strategy in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Denlinger, Kurt
482 Handwritten memo containing legal analysis prepared in anticipation of litigation re: merger of Garrett and Signal retirement plans.
HW0032494 HW0032495 Yes Attorney-Client; F, L, RWork Product
Gangone, Marie* O'Neill, Harry*
483 Memo containing legal analysis, advice, and strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
O'Neill, Harry*
484 Chart reflecting advice of counsel and containing information prepared at the request of counsel and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
485 Draft presentation containing legal analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
486 Handwritten notes containing mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
O'Neill, Harry*
Page 63 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 64 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure487 Handwritten notes containing legal strategy and mental
impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, R Work Product
O'Neill, Harry*
488 Handwritten notes containing legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
489 Handwritten notes containing legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
490 Handwritten notes containing legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
491 Handwritten notes containing legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
492 Document containing mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
493 Summaries containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: plan language.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
494 Presentation containing handwritten notes reflecting mental impressions of counsel prepared at the request of counsel and in anticipation of litigation re: Garrett Retirement Plan.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
495 Handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: potential claims and defenses.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
496 Handwritten memo containing legal analysis prepared in anticipation of litigation re: calculation of benefits under Garrett plan.
HW0032492 HW0032493 Yes Attorney-Client; F, L, RWork Product
Gangone, Marie* O'Neill, Harry*
497 Handwritten notes containing information prepared at the request of counsel re: merger of Garrett and Signal companies.
No Attorney-Client; F, L, RWork Product
Dooley, Lisa*
Page 64 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 65 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure498 Handwritten notes containing information prepared at
the request of counsel re: merger of Garrett and Signal companies.
No Attorney-Client F, RO'Neill, Harry*
499 Handwritten notes containing legal strategy and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
500 Notes containing attorney-client communications and mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
501 Draft letter containing mental impressions of counsel prepared in anticipation of litigation re: appeal of denial of administrative claims.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
502 Presentation prepared at the request of counsel and in anticipation of litigation reflecting legal analysis re: merger of Garrett and Signal plans.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
503 Summaries containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: plan language.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
504 Draft presentation containing mental impressions of counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
505 Presentation reflecting information assembled in furtherance of representation and in anticipation of litigation re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
506 Chronology prepared by counsel in anticipation of litigation re: plan amendments for purposes of providing legal advice and strategy.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
507 Notes reflecting mental impressions of counsel prepared in anticipation of litigation re: SBA offset.
No Attorney-Client; F, L, RWork Product
O'Neill, Harry*
508 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
509 Draft presentation prepared at the request of counsel and in anticipation of litigation containing mental impressions of counsel and legal advice re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
Page 65 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 66 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure510 Document summarizing legal analysis and reflecting
mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
511 Document summarizing legal analysis and reflecting mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
512 Draft letter containing information prepared in furtherance of representation and in anticipation of litigation re: denial of administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
513 Draft letter containing information prepared in furtherance of representation and in anticipation of litigation re: denial of administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
514 Draft letter containing information prepared in furtherance of representation and in anticipation of litigation re: denial of administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
515 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
516 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
517 Draft presentation containing mental impressions of counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
518 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
519 Chronology prepared by counsel in anticipation of litigation re: plan amendments for purposes of providing legal advice and strategy.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
520 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
521 Notes reflecting legal analysis and mental impressions of counsel re: merger of Garrett and Signal retirement plans prepared in anticipation of litigation.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
Page 66 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 67 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure522 Analysis prepared at the request of counsel in
anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
523 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
524 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
525 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
526 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
527 Presentation containing information prepared at the request of counsel and in anticipation of litigation re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
528 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
529 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
530 Document containing legal analysis and reflecting mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
531 Draft letter prepared in anticipation of litigation re: resolution of administrative claim concerning SBA benefits.
No Attorney-Client; F, L, Work Product
O'Melveny & Myers*
532 Handwritten notes reflecting communications with counsel for purposes of securing legal advice and in anticipation of litigation re: SBA offset claim.
HW0055007 HW0055009 Yes Attorney-Client; F, L, RWork Product
Greenman, Jane*
533 Handwritten notes containing mental impressions of counsel and legal strategy re: Signal Plan.
No Attorney-Client F, RO'Melveny & Myers*
Page 67 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 68 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure534 Handwritten notes containing mental impressions of
counsel and legal strategy re: Signal Plan.No Attorney-Client F, RO'Melveny & Myers*
535 Index of documents compiled in anticipation of litigation and attorney-client communications re: administrative claims.
No Attorney-Client; F, L, RWork Product
Gangone, Marie* Vine, John* O'Neill, Harry*
Covert, Kevin*
536 Handwritten notes and excerpt of Garrett Savings Plan reflecting legal advice re: merger of Garrett and Signal plans.
No Attorney-Client F, RDebevoise & Plimpton*
537 Draft plan document with handwritten notes reflecting legal advice and analysis re: proposed plan language.
No Attorney-Client F, RDebevoise & Plimpton*
538 Draft plan document with handwritten notes reflecting legal advice and analysis re: proposed plan language.
No Attorney-Client F, RDebevoise & Plimpton*
539 Draft plan document with handwritten notes reflecting legal advice and analysis re: proposed plan language.
No Attorney-Client F, RDebevoise & Plimpton*
540 Draft presentation prepared at the request of counsel and in anticipation of litigation reflecting mental impressions of counsel and legal advice re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
541 File containing handwritten notes, legal memoranda, case law, and plan documents compiled by counsel in anticipation of litigation re: administrative claims.
No Attorney-Client; F, RWork Product
Vine, John*
542 Draft correspondence providing legal advice and reflecting mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, LWork Product
Shea, Richard* Covert, Kevin*
O'Neill, Harry*
543 Documents prepared in anticipation of litigation and containing mental impressions of counsel re: administrative claims.
No Attorney-Client; F, LWork Product
Vine, John*
544 Document containing legal analysis and mental impressions of counsel and prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, L,Work Product
Covington & Burling*
545 Document containing legal analysis and mental impressions of counsel and prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
Page 68 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 69 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure546 Document containing legal analysis and reflecting
mental impressions of counsel prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, RWork Product
Covington & Burling*
547 Summaries containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: SBA.
HW0055130 HW0055182 Yes Attorney-Client; F, L, RWork Product
Covington & Burling*
548 Summaries containing mental impressions of counsel and legal strategy prepared in anticipation of litigation re: SBA.
HW0055130 HW0055132 Yes Attorney-Client; F, L, RWork Product
Covington & Burling*
549 Analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
550 Analysis prepared at the request of counsel and in anticipation of litigation re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
551 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
552 Documents containing mental impressions of counsel prepared in anticipation of litigation re: summary plan descriptions.
HW0026129 HW0026373 Yes Attorney-Client; F, L, RWork Product
O'Neill, Harry*
553 Draft presentation reflecting legal strategy and containing information prepared at the request of counsel and in anticipation of litigation re: Garrett and Signal retirement plans.
No Attorney-Client; F, L, RWork Product
Mathis, Kathleen
554 Draft presentation containing information prepared at the request of counsel and in anticipation of litigation re: SBA benefit calculations.
No Attorney-Client; F, L, RWork Product
Mathis, Kathleen
555 Presentation reflecting advice of counsel and containing information prepared at the request of counsel and in anticipation of litigation re: merger of Garrett and Signal plans.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
556 Chart containing information prepared at the request of counsel and in anticipation of litigation re: SBA offset.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
557 Chart and notes containing information prepared at the request of counsel re: SBA offset calculation.
No Attorney-Client F, RMathis, Kathleen
Page 69 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 70 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure558 Notes reflecting legal analysis and mental impressions
of counsel prepared in anticipation of litigation re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
559 Chart containing information prepared at the request of counsel re: SBA offset calculation.
No Attorney-Client F, O, RHewitt Associates
560 Fax containing information prepared at the request of counsel and in anticipation of litigation re: communications with employees re: SBA.
No Attorney-Client F, LBurnelko, Cindy O'Neill, Harry*
Gangone, Marie*
561 Presentation reflecting information assembled in furtherance of representation and legal analysis re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
562 Notes containing legal analysis and reflecting legal strategy prepared in anticipation of litigation re: SBA lawsuit.
No Attorney-Client; F, L, RWork Product
Burnelko, Cindy
563 Presentation providing information prepared at the request of counsel and in anticipation of litigation re: SBA offset calculation.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
564 Presentation containing legal advice re: Allied Signal relationship with labor unions and including discussion of SBA.
No Attorney-Client F, RChapman, Craig
565 Notes reflecting legal analysis and mental impressions of counsel re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
566 Notes reflecting legal analysis and mental impressions of counsel re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
567 Notes reflecting legal analysis and mental impressions of counsel re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
568 Notes reflecting legal analysis and mental impressions of counsel re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
569 Notes reflecting legal analysis and mental impressions of counsel re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Sonnenshein, Eric*
570 Draft memo prepared in anticipation of litigation providing legal advice and analysis re: administrative claims.
No Attorney-Client; F, LWork Product
Covington & Burling*
Page 70 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 71 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure571 Notes reflecting legal analysis and mental impressions
of counsel re: administrative claims.No Attorney-Client; F, L, R
Work ProductCovington & Burling*
572 Notes reflecting legal analysis and mental impressions of counsel re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
573 Notes containing legal analysis and reflecting legal strategy prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Burnelko, Cindy
574 Summary of plan provisions prepared by counsel and reflecting legal strategy and mental impressions of counsel prepared in anticipation of litigation.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
575 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F,O, L, RWork Product
Hewitt Associates
576 Analysis prepared at the request of counsel in anticipation of litigation and for purposes of providing legal advice re: administrative claims.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
577 Draft presentation containing mental impressions of counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
578 Document containing legal analysis and mental impressions of counsel and prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
579 Document containing legal analysis and mental impressions of counsel and prepared in anticipation of litigation re: SBA claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
580 Draft presentation containing mental impressions of counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F, O, L, RWork Product
Hewitt Associates
581 Presentation reflecting information assembled in furtherance of representation and in anticipation of litigation re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
582 Draft presentation containing mental impressions of counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
Page 71 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 72 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure583 Draft presentation containing mental impressions of
counsel and prepared at the request of counsel in anticipation of litigation re: SBA plan.
No Attorney-Client; F,O, L, RWork Product
Hewitt Associates
584 Handwritten notes containing legal analysis and strategy prepared in anticipation of litigation re: offset calculations.
No Attorney-Client; F, L, RWork Product
Mathis, Kathleen
585 Presentation reflecting information assembled in furtherance of representation and legal analysis re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
586 Chart and handwritten notes containing information prepared at the request of counsel and in anticipation of litigation re: SBA offset calculation.
No Attorney-Client; F, L, RWork Product
Mathis, Kathleen
587 Report reflecting information assembled in furtherance of representation and in anticipation of litigation re: Garrett plan history.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
588 Notes reflecting mental impressions of counsel prepared in anticipation of litigation re: retirement plan appeals process.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
589 Report containing information assembled in furtherance of representation and in anticipation of litigation re: history of Garrett plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
590 Notes reflecting legal strategy and analysis prepared in anticipation of litigation re: administrative claims.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
591 Notes reflecting legal analysis and mental impressions of counsel prepared in anticipation of litigation re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
592 Notes reflecting legal analysis and mental impressions of counsel prepared in anticipation of litigation re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
593 Notes reflecting legal analysis and mental impressions of counsel prepared in anticipation of litigation re: Garrett retirement and SBA plan terms.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
594 Memo containing handwritten notes reflecting mental impressions of counsel prepared in anticipation of litigation re: Exhibit B to Garrett plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
Page 72 of 73(*) indicates attorneys and legal professionalsTuesday, May 13, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 73 of 74
No. Date Author Addressee Copyee Description Bates Begin Bates End Redacted Privilege Reason for Disclosure595 Notes reflecting legal analysis and mental impressions
of counsel re: administrative claims.No Attorney-Client; F, L, R
Work ProductCovington & Burling*
596 Presentation reflecting information assembled in furtherance of representation and legal analysis re: SBA plan.
No Attorney-Client; F, L, RWork Product
Covington & Burling*
597 3/30/1984 Draft plan document reflecting legal analysis and advice re: proposed restated Signal retirement plan.
HW0056825 HW0056886 Yes Attorney-Client F, P, U, RThe Signal Companies, Inc. Retirement Plan Committee
Kipps, Clarence*
598 5/10/1984 Letter from counsel requesting information re: merger of Garrett and Signal retirement plans for purposes of developing legal advice in furtherance of representation.
HW0056986 HW0056986 Yes Attorney-Client F, P, U, RKipps, Clarence* Freundlich, B. David*
Page 73 of 73(*) indicates attorneys and legal professionalsTuesday, May 15, 2008Reasons for Disclosure:F=Fiduciary Exception to Attorney-Client PrivilegeL=Litigation Not Reasonably AnticipatedP=Post-Dates 2/4/84 Signal Plan Amendment
R=No Legal Advice, No Lawyer Involvement or Appears Capable of Redaction to Remove AdviceE=Distributed to or Sent by Lower Level Employees
O=Distributed to Outside Actuaries, Consultants and AdministratorsU=Unknown Distribution, N/A= Plaintiffs Not Seeking Disclsoure
Case 2:04-cv-00424-ROS Document 451-3 Filed 05/16/2008 Page 74 of 74
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