RESPONSE to Motion re [332] MOTION to Seal Doc. 330 & 331 filed by United States of America. (Attachments: # (1) Exhibit 17 (redacted), # (2) Exhibit 18 (redacted), # (3) Exhibit 23 (redacted), # (4) Exhibit 24 (redacted))(Teitelbaum, Aaron)
Page 1 PageID# No.
Bates No.
Custodian(s) Author(s)/Fr To
om
ARMY-ADS- Glenna Wood Mohamed
(Moe) AlDarsani**
CC
BCC Date
Subject
2/6/
Attorney
Involved
Mohamed
(Moe) AlDarsani**, Scott
Handley
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
Discussions between Army attorneys and
marketing personnel regarding the litigation
hold issued in this case.
Christopher
321 CMS-ADS0000061420; Koepke
CMS-ADS0000061363;
CMS-ADS
Christopher
Koepke
W. Charles
Bailey**;
Catherine
Howden
1/3/
RE: Short Call
with DOJ
Antitrust for
Background Info.
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
322 CMS-ADS0000063193; Koepke
CMS-ADS0000063134;
CMS-ADS
Christopher
Koepke
W. Charles
Bailey**;
Catherine
Howden
1/3/
RE: Short Call
with DOJ
Antitrust for
Background Info.
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 1 of 16Page 2 PageID# No.
Bates No.
Custodian(s) Author(s)/Fr To
om
Christopher W. Charles
Catherine
323 CMS-ADSBailey**
Howden
0000064696; Koepke
CMS-ADS0000064424;
CMS-ADS
CC
BCC Date
Christopher Koepke
1/3/
Subject
Attorney
Involved
W. Charles
RE: Short Call
Bailey**;
with DOJ
Kenneth
Antitrust for
Background Info. Whitley**
Privilege(s)
Asserted
Attorney
Client
Privilege Basis
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
324 CMS-ADS0000064933; Koepke
CMS-ADS0000064661;
CMS-ADS
Michael
Wolin**
W. Charles
Bailey**
Nierlich, George (ATR) ;
Hough, Marymichael (ATR) ;
Christopher Koepke; Catherine
Howden; Michael Wolin**
1/3/
RE: Inquiry from
Department of
Justice, Antitrust
Division
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
325 CMS-ADS0000066925; Koepke
CMS-ADS0000066653;
CMS-ADS
W. Charles
Bailey**
Michael
Wolin**
Nierlich, George (ATR) ;
Hough, Marymichael (ATR) ;
Christopher Koepke; Catherine
Howden
1/3/
RE: Inquiry from
Department of
Justice, Antitrust
Division
W. Charles
Bailey**;
Kenneth
Whitley**;
Michael
Wolin**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 2 of 16Page 3 PageID# 5409Page 4 PageID# No.
Bates No.
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Catherine
332 CMS-ADSKoepke
Howden
0000151137; Koepke
CMS-ADS0000134924;
CMS-ADS
Christopher
333 CMS-ADS0000244081; Koepke
CMS-ADS0000205600;
CMS-ADS
W. Charles
Bailey**
Christopher
Koepke;
Catherine
Howden
1173 USPS-ADS
Christopher
Karpenko
Kimberly
Workinger
Christopher
Karpenko
1174 USPS-ADS
Christopher
Karpenko
Michael
Wolin**
Kimberly
Workinger
CC
BCC Date
1/3/
Subject
Attorney
Involved
W. Charles
RE: Short Call
Bailey**;
with DOJ
Kenneth
Antitrust for
Background Info. Whitley**;
Michael
Wolin**
Privilege(s)
Asserted
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
W. Charles
Bailey**;
Kenneth
Whitley**;
Michael
Wolin**
1/3/
RE: Short Call
with DOJ
Antitrust for
Background Info.
Maria Votsch**
1/6/
Maria Votsch** Attorney
RE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Hough, Marymichael (ATR) ;
Christopher Karpenko; Michael
Wolin**
1/6/
Michael
RE:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 4 of
Privilege Basis
Confidential attorney-client communication
regarding information request from U.S. DOJ
in connection with U.S. v. Google litigation
Confidential attorney-client communication
Attorney
Client;Attorn regarding information request from U.S. DOJ
in connection with U.S. v. Google litigation
ey Work
Product;
Deliberative
ProcessPage 5 PageID# No.
Bates No.
Custodian(s) Author(s)/Fr
om
Michael
Brian
Pasco;Christo Weaver**
pher
Karpenko;Mi
ke Bottenberg
To
CC
Maria Votsch**
1/17/
RE:
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Maria Votsch**
1/13/
RE:
[Confidential]
Preparing for
litigation hold in
potential Google
advertising
litigation
Maria Votsch**
1/6/
Maria Votsch** AttorneyRE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Confidential communication regarding
information request for U.S. v. Google
litigation
Kimberly
Workinger
1/6/
RE:
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
AttorneyClient
Confidential communication regarding
information request for U.S. v. Google
litigation
1/6/
Maria Votsch** AttorneyRE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Confidential communication regarding
information request for U.S. v. Google
litigation
1/13/
Maria Votsch** Attorney[Confidential]
Client
Preparing for
litigation hold in
potential Google
advertising
litigation
Confidential communication between attorney
and client containing legal advice regarding
and confidential communication describing
privileged communications regarding and
document prepared by attorney in connection
with litigation hold email from USPS attorney
to other USPS attorneys and Karpenko with
instructions for preserving docs and
discussion of potential litigation.
1176 USPS-ADS
Michael
Brian
Pasco;Christo Weaver**
pher
Karpenko;Mi
ke Bottenberg
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco
1177 USPS-ADS
Christopher
Karpenko
Kimberly
Workinger
1178 USPS-ADS
Christopher
Karpenko
1179 USPS-ADS
Christopher
Karpenko
Maria
Votsch**
Christopher
Karpenko;
Kimberly
Workinger
1180 USPS-ADS
Brian
Pasco;Mike
Bottenberg
Michael
Weaver**
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
1175 USPS-ADS
Christopher
Karpenko
BCC Date
Maria Votsch**
Subject
Attorney
Involved
Chase
Pritchett**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 5 of
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
Confidential communication between attorney
and client containing legal advice regarding
and confidential communication describing
privileged communications regarding and
document prepared by attorney in connection
with litigation hold email from USPS attorney
to other USPS attorneys and Karpenko with
instructions for preserving docs and
discussion of potential litigation.Page 6 PageID# No.
Bates No.
1181 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Kimberly
Michael
Karpenko
Workinger
Wolin**
CC
BCC Date
Subject
Attorney
Involved
Michael
Wolin**
Privilege(s)
Asserted
Attorney
Client
Privilege Basis
Confidential communication regarding
information request for U.S. v. Google
litigation
Hough, Marymichael (ATR) ;
Christopher Karpenko
1/6/
RE:
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Maria Votsch**
1/17/
Chase
RE:
Pritchett**
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Attorney
Client;Attorn
ey Work
Product
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
Barry Dickey; Samuel Schmidt**
9/16/
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1182 USPS-ADS
Christopher
Brian
Pasco;Christo Karpenko
pher
Karpenko;Mi
ke Bottenberg
1183 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Michael
Weaver**;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Kevin
Traskos**
1184 USPS-ADS
Christopher
Karpenko
Kevin
Calamoneri
Christopher
Karpenko
9/15/
Re: Colo v USPS - Kevin
strategy Q
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1185 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/
Lauren
Dickey**;
Kevin
Traskos**
Attorney
Client
Confidential communication between attorney
and client to obtain legal advice regarding
litigation with Colorado over election mail
communications in 2020.
1186 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
Kevin
Traskos**;
Christopher
Karpenko;
Kevin
Calamoneri
FW: Google
Analytics on
Election Mail site
09/13/2020 confidential
RE: CO v USPS draft response re
radio ad?
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1187 USPS-ADS
Christopher
Karpenko
Barry Dickey Christopher
Karpenko
9/17/
Kevin
[EXTERNAL]
RE: CO v USPS - Traskos**
draft response re
radio ad?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1188 USPS-ADS
Christopher
Karpenko
Kevin
Traskos**
9/17/
Kevin
[EXTERNAL]
FW: USPS media Traskos**
campaign - share
with state?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko;
Samuel
Schmidt**
Caroline R. Brownlie**
Barry Dickey
9/17/
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 6 of 1Page 7 PageID# No.
Bates No.
CC
1189 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Barry Dickey
Karpenko
Karpenko
BCC Date
Samuel Schmidt**
9/14/
1190 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey
Samuel Schmidt**
9/14/
1191 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey
Samuel Schmidt**
1192 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
1193 USPS-ADS
Christopher
Karpenko
1194 USPS-ADS
1195 USPS-ADS
Subject
Attorney
Involved
Samuel
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/14/
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
9/18/
USPS Settlement Samuel
Compliance
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
Christopher
Karpenko
9/18/
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Christopher
Karpenko
Samuel
Schmidt**
Kevin
Traskos**;
Christopher
Karpenko;
Kevin
Calamoneri
Caroline R. Brownlie**
9/17/
RE: CO v USPS - Kevin
draft response re Traskos**
radio ad?
Christopher
Karpenko
Kevin
Traskos**
Samuel
Schmidt**
Christopher Karpenko; Barry Dickey
9/17/
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign - share
with state?
RE:
[EXTERNAL]
RE: Google
Analytics on
Election Mail site
09/13/2020 confidential
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 7 of
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Confidential communication between attorney
and client containing legal advice regarding
and document prepared by attorney in
connection with USPS litigation with
Colorado concerning vote by mail
communications
Confidential communication between attorney
Attorney
Client;Attorn and client to obtain legal advice regarding and
confidential communication between attorney
ey Work
and client containing legal advice regarding
Product
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.Page 8 PageID# No.
Bates No.
1196 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Barry Dickey
Karpenko
Karpenko
1197 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
1198 USPS-ADS
Christopher
Karpenko
1199 USPS-ADS
Christopher
Karpenko
1200 USPS-ADS
Christopher
Karpenko
1201 USPS-ADS
CC
BCC Date
Kevin Traskos**; Samuel Schmidt**
9/16/
Barry Dickey
Samuel Schmidt**
9/13/
Christopher Barry Dickey
Karpenko
Christopher
Karpenko
ADolce
Barry Dickey Christopher
Karpenko
Samuel Schmidt**
9/13/
Samuel Schmidt**
9/13/
Barry Dickey Christopher
Barry Dickey Karpenko
ADolce
Samuel Schmidt**
Christopher
Karpenko
Kevin
Traskos**
Christopher
Karpenko
Barry Dickey; Samuel Schmidt**
1202 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
1203 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Subject
Attorney
Involved
RE: USPS media Samuel
campaign
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
RE: DRAFT
Declaration of
Chirs
Karpenko.docx
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Samuel
Schmidt**
Samuel
Schmidt**
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Christ 9/13/opher
Karpe
nko
Samuel
Schmidt**
Document prepared by attorney in connection
Attorney
Client;Attorn with draft declaration prepared in connection
with USPS-State of Colorado litigation.
ey Work
Product
9/17/
Samuel
[EXTERNAL]
Schmidt**
USPS media
campaign - share
with state?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Shirley Dixon
9/14/
Kevin
FW: Google
Traskos**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Shirley Dixon
9/13/
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
[EXTERNAL]
DRAFT
Declaration of
Chirs
Karpenko.docx
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 8 of 16Page 9 PageID# No.
Bates No.
1204 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Kevin
Karpenko
Karpenko
Traskos**;
Samuel
Schmidt**
1205 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
1206 USPS-ADS
Christopher
Karpenko
Kevin
Traskos**
1207 USPS-ADS
Christopher
Karpenko
1208 USPS-ADS
CC
BCC Date
Subject
Attorney
Involved
RE: CO v USPS - Kevin
draft response re Traskos**;
Samuel
radio ad?
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Caroline R. Brownlie**
9/17/
Kevin
Traskos**
Christopher Karpenko; Barry Dickey
9/17/
RE: USPS media Kevin
campaign - share Traskos**;
Samuel
with state?
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Barry Dickey; Samuel Schmidt**
9/16/
Kevin
[EXTERNAL]
FW: USPS media Traskos**;
Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey Christopher
Karpenko;
Samuel
Schmidt**
9/12/
Kevin
[EXTERNAL]
RE: Postal Mailer Traskos**;
- Election Ballots Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Christopher Barry Dickey;
Samuel
Karpenko
Christopher Schmidt**
Karpenko
Flak, Don West
Columbia, SC
9/14/
Kevin
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client containing legal advice regarding
and document prepared by attorney in
connection with USPS litigation with
Colorado concerning vote by mail
communications.
1209 USPS-ADS
Christopher
Karpenko
Thomas
Marshall**
Samuel
Schmidt**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/
RE: USPS media Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1210 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/17/
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 9 of 16Page 10 PageID# No.
Bates No.
1211 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Barry Dickey Christopher
Karpenko
Karpenko
CC
BCC Date
1212 USPS-ADS
Christopher
Karpenko
Thomas
Marshall**
1213 USPS-ADS
Christopher
Karpenko
Barry Dickey Kevin
Traskos**;
Christopher
Karpenko;
Samuel
Schmidt**
1214 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/16/
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1215 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
9/14/
RE: USPS media Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1216 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/
Samuel
FW: Google
Schmidt**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1217 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Kevin Traskos**; Samuel Schmidt**
Seaver, Kristin A - Washington, DC
Christopher
>; Kevin
Karpenko;
Steven Monteith Calamoneri
Attorney
Involved
Kevin
[EXTERNAL]
RE: USPS media Traskos**;
Samuel
campaign
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/14/
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/17/
[EXTERNAL]
RE: USPS media
campaign - share
with state?
Kevin
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/16/
Subject
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 10 of
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.Page 11 PageID# No.
Bates No.
1218 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko
1219 USPS-ADS
Christopher
Karpenko
Kevin
Traskos**
1220 USPS-ADS
Christopher
Karpenko
1221 USPS-ADS
CC
BCC Date
Subject
Attorney
Involved
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey; Samuel Schmidt**
9/16/
Christopher
Karpenko
Samuel Schmidt**
9/16/
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Thomas
Marshall**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/
RE: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**;
Kevin
Calamoneri;
Samuel
Schmidt**
Samuel Schmidt**
9/17/
RE: CO v USPS - Kevin
draft response re Traskos**
radio ad?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1222 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**;
Samuel
Schmidt**
Caroline R. Brownlie**; Kevin
Calamoneri; Samuel Schmidt**
9/15/
Kevin
RE: Proposed
response to Colo Traskos**
email re USPS
media campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1223 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/12/
RE: Postal Mailer Kevin
- Election Ballots Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1224 USPS-ADS
Christopher
Karpenko
Kevin
Traskos**
Christopher
Karpenko
9/17/
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey; Samuel Schmidt**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 11 of 16Page 12 PageID# No.
Bates No.
1225 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko
1226 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
1227 USPS-ADS
Christopher
Karpenko
1228 USPS-ADS
CC
BCC Date
Subject
Attorney
Involved
Samuel
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel Schmidt**
9/15/
[EXTERNAL]
FW: Colo v
USPS - strategy Q
Barry Dickey
Christopher Karpenko
9/13/
Samuel
Schmidt**
Barry Dickey
Christopher Karpenko
9/13/
FW: DRAFT
Declaration of
Chirs
Karpenko.docx
Christopher
Karpenko
Thomas
Marshall**
Samuel
Schmidt**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/
RE: USPS media Kevin
campaign
Traskos**
1229 USPS-ADS
Christopher
Karpenko
Thomas
Marshall**
Seaver, Kristin A - Washington, DC
Christopher
Kevin
Karpenko;
Steven Monteith Calamoneri
9/14/
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1230 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey;
Kevin
Traskos**;
Samuel
Schmidt**
Caroline R. Brownlie**; Kevin
Calamoneri; Samuel Schmidt**
9/15/
Kevin
RE: Proposed
response to Colo Traskos**
email re USPS
media campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1231 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Thomas
Marshall**
Seaver, Kristin A - Washington, DC
; Kevin
Calamoneri
9/14/
RE: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1232 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/16/
RE: USPS media Kevin
Traskos**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 12 of
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.Page 13 PageID# No.
Bates No.
CC
1233 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Kevin
Karpenko
Karpenko
Calamoneri
1234 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
1235 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
Rupert, David G
- Denver, CO
<
;
Jeffrey Adams;
Christopher
Karpenko
Rupert, David G
- Denver, CO
;
Jeffrey Adams;
Christopher
Karpenko
Barry Dickey;
Samuel
Schmidt**
BCC Date
Attorney
Involved
RE: Colo v USPS Kevin
- strategy Q
Traskos**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/14/
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/11/
Samuel
Schmidt**
AttorneyClient
Confidential communication between attorney
and client related to Colorado vote by mail
litigation.
9/14/
Samuel
FW: Google
Schmidt**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/15/
Subject
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1236 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
1237 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey;
Samuel
Schmidt**
9/13/
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1238 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Steven
Monteith;
Thomas
Marshall**
9/13/
Google Analytics Kevin
on Election Mail Traskos**
site 09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1239 USPS-ADS
Christopher
Karpenko
Christopher
Karpenko
Steven
Monteith;
Thomas
Marshall**
9/13/
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 13 of 16Page 14 PageID# No.
Bates No.
1240 USPS-ADS
Custodian(s) Author(s)/Fr To
CC
om
Samuel Schmidt**
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko; Barry
Dickey
Kevin Traskos**; Samuel Schmidt**
BCC Date
Attorney
Involved
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/16/
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/16/
Subject
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1241 USPS-ADS
Christopher
Karpenko
Barry Dickey Christopher
Karpenko
1242 USPS-ADS
Christopher
Karpenko
Samuel
Schmidt**
Christopher
Karpenko; Barry
Dickey
9/12/
RE: Postal Mailer Samuel
- Election Ballots Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1243 USPS-ADS
Brian
Pasco;Mike
Bottenberg
Kimberly
Workinger
Michael
Bottenberg;
Brian Pasco
1/6/
Michael
FW:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1244 USPS-ADS
Brian
Pasco;Mike
Bottenberg
Michael
Weaver**
1/17/
Chase
RE:
Pritchett**
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Attorney
Client;Attorn
ey Work
Product
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
1245 USPS-ADS
Brian Pasco
Christopher
Maria Votsch**
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/6/
Plus One Sell
Sheets
1246 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
1247 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
3/7/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
3/7/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 14 of 16Page 15 PageID# No.
Bates No.
1248 USPS-ADS
Custodian(s) Author(s)/Fr To
CC
om
Brian Pasco Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
BCC Date
3/7/
Subject
Attorney
Privilege(s)
Involved
Asserted
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1249 USPS-ADS
Brian Pasco
Sandra
Riley**
Lauren Banks
Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/7/
RE: Plus One Sell Sandra Riley** Attorney
Sheets
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1250 USPS-ADS
Brian Pasco
Sandra
Riley**
Lauren Banks
Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/7/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1251 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/
RE: Plus One Sell Sandra Riley** Attorney
Sheets
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1252 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1253 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1254 USPS-ADS
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1255 USPS-ADS
Mike
Bottenberg
Kimberly
Workinger;
Brian Pasco
1/6/
Michael
RE:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 15 of
Attorney
Client
Confidential communication regarding
information request for U.S. v. Google
litigationPage 16 PageID# No.
Bates No.
1256 USPS-ADS
1257 USPS-ADS
Custodian(s) Author(s)/Fr To
om
Mike
Christopher
Bottenberg
Karpenko;
Kimberly
Workinger;
Brian Pasco
CC
Christopher
Karpenko
Alexandra Reams**; Walter
Alesevich**
Christopher
Karpenko
Karen
Owczarski**;
Amity Kirby
BCC Date
Subject
Attorney
Involved
Chase
Pritchett**
1/17/
RE:
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
7/10/
RE: Stamps.com Karen Estilo
Owczarski
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 16 of
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Attorney
Client
Privilege Basis
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with DOJ attorney
discussions with agency counsel concerning
agency practices that could impact the legal
theories in the complaint
draft Stamps.com license agreement.
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 1 of 16 PageID# 5407
No.
93
Bates No.
Custodian(s) Author(s)/Fr To
om
ARMY-ADS- Glenna Wood Mohamed
0000242284
(Moe) AlDarsani**
CC
BCC Date
Subject
2/6/2023
Attorney
Involved
Mohamed
(Moe) AlDarsani**, Scott
Handley
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
Discussions between Army attorneys and
marketing personnel regarding the litigation
hold issued in this case.
Christopher
321 CMS-ADS0000061420; Koepke
CMS-ADS0000061363;
CMS-ADS0000183413
Christopher
Koepke
W. Charles
Bailey**;
Catherine
Howden
1/3/2023
RE: Short Call
with DOJ
Antitrust for
Background Info.
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
322 CMS-ADS0000063193; Koepke
CMS-ADS0000063134;
CMS-ADS0000185184
Christopher
Koepke
W. Charles
Bailey**;
Catherine
Howden
1/3/2023
RE: Short Call
with DOJ
Antitrust for
Background Info.
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 1 of 16
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 2 of 16 PageID# 5408
No.
Bates No.
Custodian(s) Author(s)/Fr To
om
Christopher W. Charles
Catherine
323 CMS-ADSBailey**
Howden
0000064696; Koepke
CMS-ADS0000064424;
CMS-ADS0000186474
CC
BCC Date
Christopher Koepke
1/3/2023
Subject
Attorney
Involved
W. Charles
RE: Short Call
Bailey**;
with DOJ
Kenneth
Antitrust for
Background Info. Whitley**
Privilege(s)
Asserted
Attorney
Client
Privilege Basis
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
324 CMS-ADS0000064933; Koepke
CMS-ADS0000064661;
CMS-ADS0000186711
Michael
Wolin**
W. Charles
Bailey**
Nierlich, George (ATR)
;
Hough, Marymichael (ATR)
;
Christopher Koepke; Catherine
Howden; Michael Wolin**
1/3/2023
RE: Inquiry from
Department of
Justice, Antitrust
Division
W. Charles
Bailey**;
Kenneth
Whitley**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Christopher
325 CMS-ADS0000066925; Koepke
CMS-ADS0000066653;
CMS-ADS0000188703
W. Charles
Bailey**
Michael
Wolin**
Nierlich, George (ATR)
;
Hough, Marymichael (ATR)
;
Christopher Koepke; Catherine
Howden
1/3/2023
RE: Inquiry from
Department of
Justice, Antitrust
Division
W. Charles
Bailey**;
Kenneth
Whitley**;
Michael
Wolin**
Attorney
Client
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 2 of 16
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 3 of 16 PageID# 5409
PDF Page 5
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 4 of 16 PageID# 5410
No.
Bates No.
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Catherine
332 CMS-ADSKoepke
Howden
0000151137; Koepke
CMS-ADS0000134924;
CMS-ADS0000256974
Christopher
333 CMS-ADS0000244081; Koepke
CMS-ADS0000205600;
CMS-ADS0000327650
W. Charles
Bailey**
Christopher
Koepke;
Catherine
Howden
1173 USPS-ADS0000139561
Christopher
Karpenko
Kimberly
Workinger
Christopher
Karpenko
1174 USPS-ADS0000139901
Christopher
Karpenko
Michael
Wolin**
Kimberly
Workinger
CC
BCC Date
1/3/2023
Subject
Attorney
Involved
W. Charles
RE: Short Call
Bailey**;
with DOJ
Kenneth
Antitrust for
Background Info. Whitley**;
Michael
Wolin**
Privilege(s)
Asserted
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
Confidential communication to counsel for
United States providing information requested
for the purpose of providing legal advice
regarding potential violation of Section 4A of
the Clayton Act related to purchases of digital
advertising by agencies and divisions of the
United States government; made in
anticipation of litigation against Google for
violations of Sections 1 and 2 of the Sherman
Act and Section 4A of the Clayton Act; and
made in the course of Antitrust Division staff
providing opinions and recommendations in
connection with decision on whether to file a
case against Google for violations of Sections
1 and 2 of the Sherman Act and Section 4A of
the Clayton Act.
W. Charles
Bailey**;
Kenneth
Whitley**;
Michael
Wolin**
1/3/2023
RE: Short Call
with DOJ
Antitrust for
Background Info.
Maria Votsch**
1/6/2023
Maria Votsch** Attorney
RE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Hough, Marymichael (ATR)
;
Christopher Karpenko; Michael
Wolin**
1/6/2023
Michael
RE:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 4 of 16
Privilege Basis
Confidential attorney-client communication
regarding information request from U.S. DOJ
in connection with U.S. v. Google litigation
Confidential attorney-client communication
Attorney
Client;Attorn regarding information request from U.S. DOJ
in connection with U.S. v. Google litigation
ey Work
Product;
Deliberative
Process
PDF Page 6
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 5 of 16 PageID# 5411
No.
Bates No.
Custodian(s) Author(s)/Fr
om
Michael
Brian
Pasco;Christo Weaver**
pher
Karpenko;Mi
ke Bottenberg
To
CC
Maria Votsch**
1/17/2023
RE:
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Maria Votsch**
1/13/2023
RE:
[Confidential]
Preparing for
litigation hold in
potential Google
advertising
litigation
Maria Votsch**
1/6/2023
Maria Votsch** AttorneyRE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Confidential communication regarding
information request for U.S. v. Google
litigation
Kimberly
Workinger
1/6/2023
RE:
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
AttorneyClient
Confidential communication regarding
information request for U.S. v. Google
litigation
1/6/2023
Maria Votsch** AttorneyRE:
Client
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Confidential communication regarding
information request for U.S. v. Google
litigation
1/13/2023
Maria Votsch** Attorney[Confidential]
Client
Preparing for
litigation hold in
potential Google
advertising
litigation
Confidential communication between attorney
and client containing legal advice regarding
and confidential communication describing
privileged communications regarding and
document prepared by attorney in connection
with litigation hold email from USPS attorney
to other USPS attorneys and Karpenko with
instructions for preserving docs and
discussion of potential litigation.
1176 USPS-ADS0000141431
Michael
Brian
Pasco;Christo Weaver**
pher
Karpenko;Mi
ke Bottenberg
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco
1177 USPS-ADS0000141520
Christopher
Karpenko
Kimberly
Workinger
1178 USPS-ADS0000142152
Christopher
Karpenko
1179 USPS-ADS0000143092
Christopher
Karpenko
Maria
Votsch**
Christopher
Karpenko;
Kimberly
Workinger
1180 USPS-ADS0000143169
Brian
Pasco;Mike
Bottenberg
Michael
Weaver**
Christopher
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
1175 USPS-ADS0000140927
Christopher
Karpenko
BCC Date
Maria Votsch**
Subject
Attorney
Involved
Chase
Pritchett**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 5 of 16
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
Confidential communication between attorney
and client containing legal advice regarding
and confidential communication describing
privileged communications regarding and
document prepared by attorney in connection
with litigation hold email from USPS attorney
to other USPS attorneys and Karpenko with
instructions for preserving docs and
discussion of potential litigation.
PDF Page 7
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 6 of 16 PageID# 5412
No.
Bates No.
1181 USPS-ADS0000144968
Custodian(s) Author(s)/Fr To
om
Christopher Kimberly
Michael
Karpenko
Workinger
Wolin**
CC
BCC Date
Subject
Attorney
Involved
Michael
Wolin**
Privilege(s)
Asserted
Attorney
Client
Privilege Basis
Confidential communication regarding
information request for U.S. v. Google
litigation
Hough, Marymichael (ATR)
;
Christopher Karpenko
1/6/2023
RE:
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Maria Votsch**
1/17/2023
Chase
RE:
Pritchett**
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Attorney
Client;Attorn
ey Work
Product
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
Barry Dickey; Samuel Schmidt**
9/16/2020
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1182 USPS-ADS0000145367
Christopher
Brian
Pasco;Christo Karpenko
pher
Karpenko;Mi
ke Bottenberg
1183 USPS-ADS0000169849
Christopher
Karpenko
Christopher
Karpenko
Michael
Weaver**;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Kevin
Traskos**
1184 USPS-ADS0000169860
Christopher
Karpenko
Kevin
Calamoneri
Christopher
Karpenko
9/15/2020
Re: Colo v USPS - Kevin
strategy Q
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1185 USPS-ADS0000169885
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/2020
Lauren
Dickey**;
Kevin
Traskos**
Attorney
Client
Confidential communication between attorney
and client to obtain legal advice regarding
litigation with Colorado over election mail
communications in 2020.
1186 USPS-ADS0000173540
Christopher
Karpenko
Samuel
Schmidt**
Kevin
Traskos**;
Christopher
Karpenko;
Kevin
Calamoneri
FW: Google
Analytics on
Election Mail site
09/13/2020 confidential
RE: CO v USPS draft response re
radio ad?
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1187 USPS-ADS0000173545
Christopher
Karpenko
Barry Dickey Christopher
Karpenko
9/17/2020
Kevin
[EXTERNAL]
RE: CO v USPS - Traskos**
draft response re
radio ad?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1188 USPS-ADS0000173550
Christopher
Karpenko
Kevin
Traskos**
9/17/2020
Kevin
[EXTERNAL]
FW: USPS media Traskos**
campaign - share
with state?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko;
Samuel
Schmidt**
Caroline R. Brownlie**
Barry Dickey
9/17/2020
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 6 of 16
PDF Page 8
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 7 of 16 PageID# 5413
No.
Bates No.
CC
1189 USPS-ADS0000173591
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Barry Dickey
Karpenko
Karpenko
BCC Date
Samuel Schmidt**
9/14/2020
1190 USPS-ADS0000173593
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey
Samuel Schmidt**
9/14/2020
1191 USPS-ADS0000173594
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey
Samuel Schmidt**
1192 USPS-ADS0000175031
Christopher
Karpenko
Samuel
Schmidt**
1193 USPS-ADS0000175037
Christopher
Karpenko
1194 USPS-ADS0000175054
1195 USPS-ADS0000175060
Subject
Attorney
Involved
Samuel
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/14/2020
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
9/18/2020
USPS Settlement Samuel
Compliance
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
Christopher
Karpenko
9/18/2020
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Christopher
Karpenko
Samuel
Schmidt**
Kevin
Traskos**;
Christopher
Karpenko;
Kevin
Calamoneri
Caroline R. Brownlie**
9/17/2020
RE: CO v USPS - Kevin
draft response re Traskos**
radio ad?
Christopher
Karpenko
Kevin
Traskos**
Samuel
Schmidt**
Christopher Karpenko; Barry Dickey
9/17/2020
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign - share
with state?
RE:
[EXTERNAL]
RE: Google
Analytics on
Election Mail site
09/13/2020 confidential
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 7 of 16
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Confidential communication between attorney
and client containing legal advice regarding
and document prepared by attorney in
connection with USPS litigation with
Colorado concerning vote by mail
communications
Confidential communication between attorney
Attorney
Client;Attorn and client to obtain legal advice regarding and
confidential communication between attorney
ey Work
and client containing legal advice regarding
Product
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
PDF Page 9
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 8 of 16 PageID# 5414
No.
Bates No.
1196 USPS-ADS0000175067
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Barry Dickey
Karpenko
Karpenko
1197 USPS-ADS0000175113
Christopher
Karpenko
Christopher
Karpenko
1198 USPS-ADS0000175114
Christopher
Karpenko
1199 USPS-ADS0000175122
Christopher
Karpenko
1200 USPS-ADS0000175123
Christopher
Karpenko
1201 USPS-ADS0000176034
CC
BCC Date
Kevin Traskos**; Samuel Schmidt**
9/16/2020
Barry Dickey
Samuel Schmidt**
9/13/2020
Christopher Barry Dickey
Karpenko
Christopher
Karpenko
ADolce
Barry Dickey Christopher
Karpenko
Samuel Schmidt**
9/13/2020
Samuel Schmidt**
9/13/2020
Barry Dickey Christopher
Barry Dickey Karpenko
ADolce
Samuel Schmidt**
Christopher
Karpenko
Kevin
Traskos**
Christopher
Karpenko
Barry Dickey; Samuel Schmidt**
1202 USPS-ADS0000177377
Christopher
Karpenko
Christopher
Karpenko
1203 USPS-ADS0000177378
Christopher
Karpenko
Christopher
Karpenko
Subject
Attorney
Involved
RE: USPS media Samuel
campaign
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
RE: DRAFT
Declaration of
Chirs
Karpenko.docx
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Samuel
Schmidt**
Samuel
Schmidt**
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Christ 9/13/2020
opher
Karpe
nko
Samuel
Schmidt**
Document prepared by attorney in connection
Attorney
Client;Attorn with draft declaration prepared in connection
with USPS-State of Colorado litigation.
ey Work
Product
9/17/2020
Samuel
[EXTERNAL]
Schmidt**
USPS media
campaign - share
with state?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Shirley Dixon
9/14/2020
Kevin
FW: Google
Traskos**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Shirley Dixon
9/13/2020
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
[EXTERNAL]
DRAFT
Declaration of
Chirs
Karpenko.docx
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 8 of 16
PDF Page 10
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 9 of 16 PageID# 5415
No.
Bates No.
1204 USPS-ADS0000178921
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Kevin
Karpenko
Karpenko
Traskos**;
Samuel
Schmidt**
1205 USPS-ADS0000178938
Christopher
Karpenko
Samuel
Schmidt**
1206 USPS-ADS0000180543
Christopher
Karpenko
Kevin
Traskos**
1207 USPS-ADS0000180562
Christopher
Karpenko
1208 USPS-ADS0000181663
CC
BCC Date
Subject
Attorney
Involved
RE: CO v USPS - Kevin
draft response re Traskos**;
Samuel
radio ad?
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Caroline R. Brownlie**
9/17/2020
Kevin
Traskos**
Christopher Karpenko; Barry Dickey
9/17/2020
RE: USPS media Kevin
campaign - share Traskos**;
Samuel
with state?
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Barry Dickey; Samuel Schmidt**
9/16/2020
Kevin
[EXTERNAL]
FW: USPS media Traskos**;
Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey Christopher
Karpenko;
Samuel
Schmidt**
9/12/2020
Kevin
[EXTERNAL]
RE: Postal Mailer Traskos**;
- Election Ballots Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Christopher Barry Dickey;
Samuel
Karpenko
Christopher Schmidt**
Karpenko
Flak, Don West
Columbia, SC
9/14/2020
Kevin
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client containing legal advice regarding
and document prepared by attorney in
connection with USPS litigation with
Colorado concerning vote by mail
communications.
1209 USPS-ADS0000181679
Christopher
Karpenko
Thomas
Marshall**
Samuel
Schmidt**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/2020
RE: USPS media Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1210 USPS-ADS0000185066
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/17/2020
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 9 of 16
PDF Page 11
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 10 of 16 PageID# 5416
No.
Bates No.
1211 USPS-ADS0000185070
Custodian(s) Author(s)/Fr To
om
Christopher Barry Dickey Christopher
Karpenko
Karpenko
CC
BCC Date
1212 USPS-ADS0000185082
Christopher
Karpenko
Thomas
Marshall**
1213 USPS-ADS0000195632
Christopher
Karpenko
Barry Dickey Kevin
Traskos**;
Christopher
Karpenko;
Samuel
Schmidt**
1214 USPS-ADS0000195640
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/16/2020
RE: USPS media Kevin
campaign
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1215 USPS-ADS0000195645
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
9/14/2020
RE: USPS media Samuel
campaign
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1216 USPS-ADS0000196490
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/2020
Samuel
FW: Google
Schmidt**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1217 USPS-ADS0000196491
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/13/2020
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Kevin Traskos**; Samuel Schmidt**
Seaver, Kristin A - Washington, DC
Christopher
>; Kevin
Karpenko;
Steven Monteith Calamoneri
Attorney
Involved
Kevin
[EXTERNAL]
RE: USPS media Traskos**;
Samuel
campaign
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/14/2020
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/17/2020
[EXTERNAL]
RE: USPS media
campaign - share
with state?
Kevin
Traskos**;
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/16/2020
Subject
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 10 of 16
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
PDF Page 12
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 11 of 16 PageID# 5417
No.
Bates No.
1218 USPS-ADS0000204713
Custodian(s) Author(s)/Fr To
om
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko
1219 USPS-ADS0000204716
Christopher
Karpenko
Kevin
Traskos**
1220 USPS-ADS0000208317
Christopher
Karpenko
1221 USPS-ADS0000209994
CC
BCC Date
Subject
Attorney
Involved
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey; Samuel Schmidt**
9/16/2020
Christopher
Karpenko
Samuel Schmidt**
9/16/2020
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Thomas
Marshall**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/2020
RE: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**;
Kevin
Calamoneri;
Samuel
Schmidt**
Samuel Schmidt**
9/17/2020
RE: CO v USPS - Kevin
draft response re Traskos**
radio ad?
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1222 USPS-ADS0000209999
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**;
Samuel
Schmidt**
Caroline R. Brownlie**; Kevin
Calamoneri; Samuel Schmidt**
9/15/2020
Kevin
RE: Proposed
response to Colo Traskos**
email re USPS
media campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1223 USPS-ADS0000210035
Christopher
Karpenko
Christopher
Karpenko
Samuel
Schmidt**
9/12/2020
RE: Postal Mailer Kevin
- Election Ballots Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1224 USPS-ADS0000211538
Christopher
Karpenko
Kevin
Traskos**
Christopher
Karpenko
9/17/2020
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Barry Dickey; Samuel Schmidt**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 11 of 16
PDF Page 13
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 12 of 16 PageID# 5418
No.
Bates No.
1225 USPS-ADS0000211551
Custodian(s) Author(s)/Fr To
om
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko
1226 USPS-ADS0000211584
Christopher
Karpenko
Samuel
Schmidt**
1227 USPS-ADS0000211586
Christopher
Karpenko
1228 USPS-ADS0000212886
CC
BCC Date
Subject
Attorney
Involved
Samuel
Schmidt**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Attorney
Client;Attorn
ey Work
Product
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel Schmidt**
9/15/2020
[EXTERNAL]
FW: Colo v
USPS - strategy Q
Barry Dickey
Christopher Karpenko
9/13/2020
Samuel
Schmidt**
Barry Dickey
Christopher Karpenko
9/13/2020
FW: DRAFT
Declaration of
Chirs
Karpenko.docx
Christopher
Karpenko
Thomas
Marshall**
Samuel
Schmidt**
Kevin Calamoneri; Caroline R.
Brownlie**
9/14/2020
RE: USPS media Kevin
campaign
Traskos**
1229 USPS-ADS0000212888
Christopher
Karpenko
Thomas
Marshall**
Seaver, Kristin A - Washington, DC
Christopher
Kevin
Karpenko;
Steven Monteith Calamoneri
9/14/2020
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1230 USPS-ADS0000213565
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey;
Kevin
Traskos**;
Samuel
Schmidt**
Caroline R. Brownlie**; Kevin
Calamoneri; Samuel Schmidt**
9/15/2020
Kevin
RE: Proposed
response to Colo Traskos**
email re USPS
media campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1231 USPS-ADS0000213570
Christopher
Karpenko
Christopher
Karpenko
Thomas
Marshall**
Seaver, Kristin A - Washington, DC
; Kevin
Calamoneri
9/14/2020
RE: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1232 USPS-ADS0000223925
Christopher
Karpenko
Christopher
Karpenko
Kevin
Traskos**
Barry Dickey; Samuel Schmidt**
9/16/2020
RE: USPS media Kevin
Traskos**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
Samuel
Schmidt**
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 12 of 16
Document prepared by attorney in connection
with draft declaration prepared in connection
with USPS-State of Colorado litigation.
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
PDF Page 14
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 13 of 16 PageID# 5419
No.
Bates No.
CC
1233 USPS-ADS0000223934
Custodian(s) Author(s)/Fr To
om
Christopher Christopher Kevin
Karpenko
Karpenko
Calamoneri
1234 USPS-ADS0000223955
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
1235 USPS-ADS0000223957
Christopher
Karpenko
Samuel
Schmidt**
Kevin Calamoneri; Thomas
Marshall**
Rupert, David G
- Denver, CO
<
;
Jeffrey Adams;
Christopher
Karpenko
Rupert, David G
- Denver, CO
;
Jeffrey Adams;
Christopher
Karpenko
Barry Dickey;
Samuel
Schmidt**
BCC Date
Attorney
Involved
RE: Colo v USPS Kevin
- strategy Q
Traskos**
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/14/2020
FW: USPS media Kevin
campaign
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/11/2020
Samuel
Schmidt**
AttorneyClient
Confidential communication between attorney
and client related to Colorado vote by mail
litigation.
9/14/2020
Samuel
FW: Google
Schmidt**
Analytics on
Election Mail site
09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/15/2020
Subject
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1236 USPS-ADS0000223967
Christopher
Karpenko
Christopher
Karpenko
1237 USPS-ADS0000223968
Christopher
Karpenko
Christopher
Karpenko
Barry Dickey;
Samuel
Schmidt**
9/13/2020
Samuel
Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1238 USPS-ADS0000223969
Christopher
Karpenko
Christopher
Karpenko
Steven
Monteith;
Thomas
Marshall**
9/13/2020
Google Analytics Kevin
on Election Mail Traskos**
site 09/13/2020 confidential
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1239 USPS-ADS0000223970
Christopher
Karpenko
Christopher
Karpenko
Steven
Monteith;
Thomas
Marshall**
9/13/2020
Kevin
Traskos**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 13 of 16
PDF Page 15
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 14 of 16 PageID# 5420
No.
Bates No.
1240 USPS-ADS0000226699
Custodian(s) Author(s)/Fr To
CC
om
Samuel Schmidt**
Christopher Kevin
Christopher
Karpenko
Traskos**
Karpenko; Barry
Dickey
Kevin Traskos**; Samuel Schmidt**
BCC Date
Attorney
Involved
Samuel
[EXTERNAL]
RE: USPS media Schmidt**
campaign
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Privilege Basis
9/16/2020
Samuel
[EXTERNAL]
FW: USPS media Schmidt**
campaign
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
9/16/2020
Subject
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1241 USPS-ADS0000277322
Christopher
Karpenko
Barry Dickey Christopher
Karpenko
1242 USPS-ADS0000277672
Christopher
Karpenko
Samuel
Schmidt**
Christopher
Karpenko; Barry
Dickey
9/12/2020
RE: Postal Mailer Samuel
- Election Ballots Schmidt**
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1243 USPS-ADS0000309562
Brian
Pasco;Mike
Bottenberg
Kimberly
Workinger
Michael
Bottenberg;
Brian Pasco
1/6/2023
Michael
FW:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication between attorney
and client containing legal advice regarding
litigation with Colorado over vote by mail
public messaging in lead-up to 2020 election.
1244 USPS-ADS0000402258
Brian
Pasco;Mike
Bottenberg
Michael
Weaver**
1/17/2023
Chase
RE:
Pritchett**
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
Attorney
Client;Attorn
ey Work
Product
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with advertising
contract terms and US v Google litigation.
1245 USPS-ADS0000507237
Brian Pasco
Christopher
Maria Votsch**
Karpenko;
Kimberly
Workinger;
Brian Pasco;
Michael
Bottenberg
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/6/2022
Plus One Sell
Sheets
1246 USPS-ADS0000507238
Brian Pasco
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
1247 USPS-ADS0000507240
Brian Pasco
Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
3/7/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
3/7/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 14 of 16
PDF Page 16
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 15 of 16 PageID# 5421
No.
Bates No.
1248 USPS-ADS0000507242
Custodian(s) Author(s)/Fr To
CC
om
Brian Pasco Lauren Banks Sandra Riley** Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
BCC Date
3/7/2022
Subject
Attorney
Privilege(s)
Involved
Asserted
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Privilege Basis
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1249 USPS-ADS0000507271
Brian Pasco
Sandra
Riley**
Lauren Banks
Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/7/2022
RE: Plus One Sell Sandra Riley** Attorney
Sheets
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1250 USPS-ADS0000507272
Brian Pasco
Sandra
Riley**
Lauren Banks
Mills, Steven E - Washington, DC
; Cecelia
Winters; Brian Pasco
6/7/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1251 USPS-ADS0000514007
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/2022
RE: Plus One Sell Sandra Riley** Attorney
Sheets
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1252 USPS-ADS0000514009
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1253 USPS-ADS0000514011
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1254 USPS-ADS0000514013
Brian Pasco
Lauren Banks Sandra Riley**; Cecelia Winters; Brian Pasco
Mills, Steven E Washington, DC
<
6/13/2022
Sandra Riley** Attorney
Client;Attorn
ey Work
Product
Confidential communication between attorney
and client to obtain legal advice regarding and
confidential communication describing
privileged communications regarding
Trademark protection of "Plus One" phrase.
1255 USPS-ADS0000518712
Mike
Bottenberg
Kimberly
Workinger;
Brian Pasco
1/6/2023
Michael
RE:
Wolin**
[EXTERNAL]
Inquiry from
Department of
Justice, Antitrust
Division
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 15 of 16
Attorney
Client
Confidential communication regarding
information request for U.S. v. Google
litigation
PDF Page 17
Case 1:23-cv-00108-LMB-JFA Document 360-1 Filed 08/30/23 Page 16 of 16 PageID# 5422
No.
Bates No.
1256 USPS-ADS0000524903
1257 USPS-ADS0000565889
Custodian(s) Author(s)/Fr To
om
Mike
Christopher
Bottenberg
Karpenko;
Kimberly
Workinger;
Brian Pasco
CC
Christopher
Karpenko
Alexandra Reams**; Walter
Alesevich**
Christopher
Karpenko
Karen
Owczarski**;
Amity Kirby
BCC Date
Subject
Attorney
Involved
Chase
Pritchett**
1/17/2023
RE:
[EXTERNAL]
RE: Discussion
with DOJ
Regarding Digital
Advertising
7/10/2018
RE: Stamps.com Karen Estilo
Owczarski
2023.08.07 FAA Privilege Log - CONFIDENTIAL (Excerpt) Page 16 of 16
Privilege(s)
Asserted
Attorney
Client;Attorn
ey Work
Product
Attorney
Client
Privilege Basis
Confidential communication describing
privileged communications regarding and
document prepared at the request of an
attorney in connection with DOJ attorney
discussions with agency counsel concerning
agency practices that could impact the legal
theories in the complaint
draft Stamps.com license agreement.
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