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# United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
No.
Bates No.
USPS-ADS2897
USPS-ADS2898
USPS-ADS2899
USPS-ADS2900
USPS-ADS2901
Custodian(s)
Christopher
Karpenko
Christopher
Karpenko;
Michael
Bottenberg
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko
** = Denotes Attorneys
Author(s)/From To
Michael Knopf
Christopher
Karpenko
Christopher
Karpenko
Lisa Catucci
Michael Knopf
CC
Lisa Catucci;
Michael Knopf
Kimberly Workinger; Maria Votsch**;
Michael Bottenberg
Michael Bottenberg; Brian Pasco; Kimberly
Workinger
Christopher
Karpenko; Michael Michael Bottenberg; Brian Pasco; Kimberly
Knopf
Workinger
Christopher
Karpenko
Date
Subject
[EXTERNAL] FW:
list of 3rd party
1/11/2023 platforms
Christopher
Karpenko
Michael Weaver**
BCC
FW: [EXTERNAL]
RE: list of 3rd party
1/17/2023 platforms
RE: [EXTERNAL]
RE: list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
Page 1 of
Contains Confidential Informaton
Privilege(s)
Attorney Involved Asserted
Privilege Basis
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractorPage 2 PageID# United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
USPS-ADS2902
ARMY-ADS2903
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
John Horning;
John Horning
Christopher
Karpenko
Lisa Catucci;
Michael Knopf
Michael Bottenberg; Brian Pasco; Kimberly
Workinger
Matthew Weinrich; Shannon Johnson; Lennox
Morris
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
list of 3rd party
1/11/2023 platforms
John Horning
Adam Jones
John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2904
John Horning;
John Horning
ARMY-ADS2905
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones
ARMY-ADS2906
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2907
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2908
John Horning;
John Horning;
Matt Weinrich
Matthew Weinrich;
Shannon Johnson
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
RE: Request for an
Online Advertising
12/29/2022 POC
John Horning
ARMY-ADS2909
Lennox Morris;
Lennox Morris Lennox Morris
Adam Jones
ARMY-ADS2910
Lennox Morris;
Lennox Morris Lennox Morris
Leeann Craig
** = Denotes Attorneys
Matthew Weinrich; Shannon Johnson; Lennox
Morris
Contains Confidential Informaton
Department of
Justice Antitrust
Division**
Michael Wolin**;
Sivram Prasad**;
George Nierlich**;
Marymichael
FW: Inquiry from
Department of Justice, Hough**; Chase
Pritchett**
1/9/2023 Antitrust Division
Page 2 of
Attorney Work
Product
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Confidential communication between attorney and client containing legal
advice regarding and document prepared at the request of an attorney in
connection with gathering information at request of and as directed by
Department of Justice Antitrust Division to assist Antitrust Division in
assessing potential damages claims by United States against Google related to
digital advertising purchasesPage 3 PagelD#
Name ization Email
Lisa Catucci Universal McCann
Michael Universal McCann
Adam Jones US
John Horni US
Leeann Crai US
Lennox Morris US
Matt Weinrich US
Matthew Weinrich US
Shannon Johnson US
Sivram Prasad** US
Chase Pritchett** Chase. Pritche
Michael Wolin** Michael. Wolin(
Nierlich** George. Nierlich( .
ichael Hough** Marymichael. Hough@usdoj.
Brian Pasco
i er
Kim Wo
Maria Votsch**
Michael Botten
Michael Weaver**
Page 3 of
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 360-2 Filed 08/30/23 Page 1 of 3 PageID# 5423
United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
No.
Bates No.
USPS-ADS2897 0000037418
USPS-ADS2898 0000141557
USPS-ADS2899 0000037567
USPS-ADS2900 0000041965
USPS-ADS2901 0000043815
Custodian(s)
Christopher
Karpenko
Christopher
Karpenko;
Michael
Bottenberg
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
Christopher
Karpenko
** = Denotes Attorneys
Author(s)/From To
Michael Knopf
Christopher
Karpenko
Christopher
Karpenko
Lisa Catucci
Michael Knopf
CC
Lisa Catucci;
Michael Knopf
Kimberly Workinger; Maria Votsch**;
Michael Bottenberg
Michael Bottenberg; Brian Pasco; Kimberly
Workinger
Christopher
Karpenko; Michael Michael Bottenberg; Brian Pasco; Kimberly
Knopf
Workinger
Christopher
Karpenko
Date
Subject
[EXTERNAL] FW:
list of 3rd party
1/11/2023 platforms
Christopher
Karpenko
Michael Weaver**
BCC
FW: [EXTERNAL]
RE: list of 3rd party
1/17/2023 platforms
RE: [EXTERNAL]
RE: list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
[EXTERNAL] RE:
list of 3rd party
1/11/2023 platforms
Page 1 of 3
Contains Confidential Informaton
Privilege(s)
Attorney Involved Asserted
Privilege Basis
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases, as well as response thereto from contractor
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 360-2 Filed 08/30/23 Page 2 of 3 PageID# 5424
United States, et al. v. Google LLC , No. 1:23-cv-108 (E.D. Va.)
Privilege Log (dated Aug. 23, 2023)
USPS-ADS2902 0000145288
ARMY-ADS2903 0000094471
Christopher
Karpenko;
Brian Pasco;
Michael
Bottenberg
John Horning;
John Horning
Christopher
Karpenko
Lisa Catucci;
Michael Knopf
Michael Bottenberg; Brian Pasco; Kimberly
Workinger
Matthew Weinrich; Shannon Johnson; Lennox
Morris
Michael Weaver**;
Michael Wolin**; Attorney Work
Chase Pritchett**
Product
Document prepared at the request of an attorney in connection with request for
information directed by DOJ relating to USPS digital advertising purchases
held on USPS's behalf by its advertising agency in anticipation of US v
Google litigation and necessary for DOJ to render legal advice to USPS in
connection with potential claims against Google, drafted during and sent
within an hour of a meeting between USPS and DOJ related to digital
advertising purchases
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
list of 3rd party
1/11/2023 platforms
John Horning
Adam Jones
John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
RE: Request for an
Online Advertising
12/27/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2904 0000094502
John Horning;
John Horning
ARMY-ADS2905 0000121371
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones
ARMY-ADS2906 0000121385
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2907 0000121389
John Horning;
John Horning;
Lennox Morris;
Matt Weinrich John Horning
Adam Jones;
Matthew Weinrich;
Shannon Johnson;
Lennox Morris
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
ARMY-ADS2908 0000121392
John Horning;
John Horning;
Matt Weinrich
Matthew Weinrich;
Shannon Johnson
RE: Request for an
Online Advertising
12/29/2022 POC
Department of
Justice Antitrust
Division**
RE: Request for an
Online Advertising
12/29/2022 POC
John Horning
ARMY-ADS2909 0000154092
Lennox Morris;
Lennox Morris Lennox Morris
Adam Jones
ARMY-ADS2910 0000154100
Lennox Morris;
Lennox Morris Lennox Morris
Leeann Craig
** = Denotes Attorneys
Matthew Weinrich; Shannon Johnson; Lennox
Morris
Contains Confidential Informaton
Department of
Justice Antitrust
Division**
Michael Wolin**;
Sivram Prasad**;
George Nierlich**;
Marymichael
FW: Inquiry from
Department of Justice, Hough**; Chase
Pritchett**
1/9/2023 Antitrust Division
Page 2 of 3
Attorney Work
Product
Attorney Work
Product
Document prepared at the request of an attorney in connection with gathering
information at request of and as directed by Department of Justice Antitrust
Division to assist Antitrust Division in assessing potential damages claims by
United States against Google related to digital advertising purchases
Confidential communication between attorney and client containing legal
advice regarding and document prepared at the request of an attorney in
connection with gathering information at request of and as directed by
Department of Justice Antitrust Division to assist Antitrust Division in
assessing potential damages claims by United States against Google related to
digital advertising purchases
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 360-2 Filed 08/30/23 Page 3 of 3 PagelD# 5425
Name ization Email
Lisa Catucci Universal McCann
Michael Universal McCann
Adam Jones US
John Horni US
Leeann Crai US
Lennox Morris US
Matt Weinrich US
Matthew Weinrich US
Shannon Johnson US
Sivram Prasad** US
Chase Pritchett** Chase. Pritche
Michael Wolin** Michael. Wolin(
Nierlich** George. Nierlich( .
ichael Hough** Marymichael. Hough@usdoj.
Brian Pasco
i er
Kim Wo
Maria Votsch**
Michael Botten
Michael Weaver**
Page 3 of 3
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