RESPONSE in Opposition re [304] MOTION to Compel filed by Commonwealth of Virginia, State of Arizona, State of California, State of Colorado, State of Connecticut, State of Illinois, State of Michigan, State of Minnesota, State of Nebraska, State of New Hampshire, State of New Jersey, State of New York, State of North Carolina, State of Rhode Island, State of Tennessee, State of Washington, State of West Virginia, United States of America. (Attachments: # (1) Affidavit Declaration of M. Wolin, # (2) Exhibit 1 - Log Excerpt)(Teitelbaum, Aaron)
Page 1 PageID# United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
No.
Bates No.
Custodian(s)
USPS-ADS2897
USPS-ADS2898
USPS-ADS2899
USPS-ADS2900
USPS-ADS2901
** = Denotes Attorneys
Author(s)/From To
CC
BCC
Date
Subject
[EXTERNAL] FW:
list of 3rd party
1/11/2023 platforms
FW: [EXTERNAL]
RE: list of 3rd party
1/17/2023 platforms
RE: [EXTERNAL]
RE: list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
Page 1 of
Contains Confidential Informaton
Privilege(s)
Attorney Involved Asserted
Privilege Basis
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractorPage 2 PageID# United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
USPS-ADS2902
list of 3rd party
1/11/2023 platforms
ARMY-ADS2903
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2904
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2905
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2906
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2907
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2908
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2909
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2910
** = Denotes Attorneys
FW: Inquiry from
Department of Justice,
1/9/2023 Antitrust Division
Page 2 of
Contains Confidential Informaton
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Confidential communication between attorney and client containing legal
advice regarding and document prepared at the request of an attorney in
connection with gathering information at request of and as directed by
Department of Justice Antitrust Division to assist Antitrust Division in
assessing potential damages claims by United States against Google related to
digital advertising purchases
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 328-2 Filed 08/23/23 Page 1 of 2 PageID# 4766
United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
No.
Bates No.
Custodian(s)
USPS-ADS2897 0000037418
USPS-ADS2898 0000141557
USPS-ADS2899 0000037567
USPS-ADS2900 0000041965
USPS-ADS2901 0000043815
** = Denotes Attorneys
Author(s)/From To
CC
BCC
Date
Subject
[EXTERNAL] FW:
list of 3rd party
1/11/2023 platforms
FW: [EXTERNAL]
RE: list of 3rd party
1/17/2023 platforms
RE: [EXTERNAL]
RE: list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
Page 1 of 3
Contains Confidential Informaton
Privilege(s)
Attorney Involved Asserted
Privilege Basis
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 328-2 Filed 08/23/23 Page 2 of 2 PageID# 4767
United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
USPS-ADS2902 0000145288
list of 3rd party
1/11/2023 platforms
ARMY-ADS2903 0000094471
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2904 0000094502
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2905 0000121371
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2906 0000121385
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2907 0000121389
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2908 0000121392
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2909 0000154092
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2910 0000154100
** = Denotes Attorneys
FW: Inquiry from
Department of Justice,
1/9/2023 Antitrust Division
Page 2 of 3
Contains Confidential Informaton
Attorney Work
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Confidential communication between attorney and client containing legal
advice regarding and document prepared at the request of an attorney in
connection with gathering information at request of and as directed by
Department of Justice Antitrust Division to assist Antitrust Division in
assessing potential damages claims by United States against Google related to
digital advertising purchases
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