United States et al v. Google LLC Document 284: Response, Attachment 1

Virginia Eastern District Court
Case No. 1:23-cv-00108-LMB-JFA
Filed July 17, 2023

Response to [280] Order,, filed by Google LLC. (Attachments: # (1) Exhibit 1 MTC Appendix, # (2) Exhibit 2 MTC Brief, # (3) Exhibit 3 MTC EX 1, # (4) Exhibit 4 MTC EX 2, # (5) Exhibit 5 MTC EX 3, # (6) Exhibit 6 MTC EX 4, # (7) Exhibit 7 MTC EX 6, # (8) Exhibit 8 MTC EX 7, # (9) Exhibit 9 MTC EX 8, # (10) Exhibit 10 MTC EX 9, # (11) Exhibit 11 MTC EX 10, # (12) Exhibit 12 MTC EX 11, # (13) Exhibit 13 MTC EX 12, # (14) Exhibit 14 MTC EX 13, # (15) Exhibit 15 MTC EX 14, # (16) Exhibit 16 MTC EX 15, # (17) Exhibit 17 MTC EX 16, # (18) Exhibit 18 MTC EX 17, # (19) Exhibit 19 MTC EX 18, # (20) Exhibit 20 MTC EX 19, # (21) Exhibit 21 MTC EX 21, # (22) Exhibit 22 MTC EX 22, # (23) Exhibit 23 MTC EX 25, # (24) Exhibit 24 MTC EX 27, # (25) Exhibit 25 MTC EX 28, # (26) Exhibit 26 MTC EX 29, # (27) Exhibit 27 MTC EX 30, # (28) Exhibit 28 MTC EX 31, # (29) Exhibit 29 MTC Reply Appendix, # (30) Exhibit 30 Opposition EX A, # (31) Exhibit 31 Opposition EX B, # (32) Exhibit 32 Opposition EX C, # (33) Exhibit 33 Reply EX 1, # (34) Exhibit 34 Reply EX 2, # (35) Exhibit 35 Reply EX 5, # (36) Exhibit 36 Reply EX 6, # (37) Exhibit 37 Reply)(Reilly, Craig)

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APPENDIX
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Privilege
Assertion
NA
Email demonstrating legal advice of
counsel regarding regulatory issues.
AC

GOOG-DOJ
GOOG-DOJ
NA
NA

GOOG-DOJ-AT
NA
NA

GOOG-DOJ-AT
GOOG-DOJ-AT
To
Privilege Log Description
Bates
X
From
CC
No.

CodeMultiple
Named
Clawbacks Project
X
NA
X
All of the documents in the Appendix have been clawed back at least once.
“AC” indicates attorney-client privilege. “WP” indicates work product.
NA
A-
NA
Draft notes seeking legal advice of counsel
regarding regulatory issues.
Draft document containing legal advice of
ESQ regarding contract
terms.
Email seeking and containing legal advice
of Ted Lazarus ESQ regarding regulatory
issues.
Information compiled in order to ballpark
the financial cost of a potential remedy in
response to active government
investigations, prepared at the direction of
Ted Lazarus, ESQ and in anticipation of
litigation. The compiled information,
which did not exist in the ordinary course
of business and would not have been
compiled but for the active government
investigations and anticipated litigation,
reflects the opinion work product of Ted
Lazarus, ESQ and
, ESQ
because it reveals legal strategy and the
nature of the remedy.
AC
AC
AC
WP
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Bates

GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
CodeMultiple
Named
Clawbacks Project
From
X
To
CC
NA
NA
NA
NA
X
X
google docs m>
NA
m>
NA
Privilege Log Description
Document and draft correspondence
seeking and reflecting legal advice and
opinion work product of Ted Lazarus ESQ
regarding potential remedy in response to
active government investigations, prepared
in anticipation of litigation.
Presentation seeking and revealing legal
advice of
ESQ regarding
legal aspects of product development.
Email gathering information to assess cost
of proposed remedy to resolve active
government investigations, undertaken in
anticipation of litigation. This email
reveals the underlying legal strategy and
opinion work product of Ted Lazarus, ESQ
and
, ESQ in that it reveals
the nature of the remedy being assessed.
Email discussing potential remedy and
reflecting opinion work product of counsel
in response to an active government
investigation by the French Competition
Authority and in anticipation of litigation.
Email seeking and containing legal advice
of Ted Lazarus ESQ regarding compliance
with competition laws.
Email chain regarding potential remedy in
response to active government
investigations and in anticipation of
litigation, reflecting opinion work product
of Kent Walker ESQ and Ted Lazarus
ESQ, prepared in anticipation of litigation.
X
A-
Privilege
Assertion
AC, WP
AC
WP
AC, WP
AC
AC, WP
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Bates
CodeMultiple
Named
Clawbacks Project
From
To
m>
CC

GOOG-DOJ-AT
X

GOOG-DOJ-AT
X
NA
NA

GOOG-DOJ-AT
X
NA
NA

GOOG-DOJ-AT
X
NA
X
NA
A-
Privilege Log Description
Email reflecting comments on draft
presentation regarding remedy to resolve
active government investigations,
undertaken at the direction of Ted Lazarus,
ESQ and in anticipation of litigation. This
email reveals opinion work product of Ted
Lazarus, ESQ and
, ESQ
in that it reveals legal strategy and the
nature of the remedy, which would not
have been considered but for the existence
of active government investigations and
anticipated litigation.
Document revealing legal advice of
counsel regarding settlement negotiation
with FCA.
Presentation reflecting and containing
opinion work product of and reflecting
legal strategy and advice of Ted Lazarus
ESQ and
ESQ regarding
potential remedies to resolve active
government investigations, prepared in
anticipation of litigation.
Email reflecting remedy project
undertaken in response to active
government investigations and in
anticipation of litigation.
Privilege
Assertion
WP
AC
AC; WP
AC, WP
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Bates
CodeMultiple
Named
Clawbacks Project
CC
Privilege Log Description
Privilege
Assertion
NA
Email revealing legal advice and opinion
work product of competition counsel and
project undertaken in anticipation of
litigation, in response to active government
investigations.
AC, WP
NA
Employee performance evaluation
reflecting remedy projects undertaken in
response to active government
investigations and in anticipation of
litigation.
WP
NA
Email reflecting remedy project
undertaken in response to active
government investigations and in
anticipation of litigation.
AC, WP
X
Portions of email revealing advice of
competition counsel and project
undertaken in anticipation of litigation, in
response to active government
investigations.
AC, WP
X
Email revealing legal advice of counsel
regarding legal aspects of product
development.
AC
From
To
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
GOOG-DOJ-AT
X
X
X
X
X
NA
X
NA
A-4
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Bates

GOOG-DOJ
CodeMultiple
Named
Clawbacks Project
From
To
X
A-
CC
Privilege Log Description
Privilege
Assertion
Email discussion revealing legal advice of
counsel regarding product development.
AC
Space
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Issues Laws Cases Pro Articles Firms Entities
 

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