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Contract analysis / email-osei-to-deluca-meet-confer-privilege.eml
email-osei-to-deluca-meet-confer-privilege.eml
High · 1
Medium · 0
Standard · 0
1. In advance of the meeting, each side would exchange exemplar documents or more detailed
1. In advance of the meeting, each side would exchange exemplar documents or more detailed privilege log descriptions for a representative sample of disputed entries, to facilitate focused discussion.
2. At the meeting, we would discuss whether any withheld documents on either side can be p
2. At the meeting, we would discuss whether any withheld documents on either side can be produced in redacted form — for example, redacting privileged legal advice while producing underlying factual content — as a means of narrowing the dispute.
3. To the extent the parties are unable to resolve all disputes through the meet and confe
High
⚑ Non-compete / exclusivity restraint
3. To the extent the parties are unable to resolve all disputes through the meet and confer, we would discuss whether to jointly propose an in camera review by Justice Ricci as an alternative to full briefing on a motion to compel, which may be a more efficient path to resolution for all concerned. I want to emphasize that Northgate approaches this process in good faith and with a genuine willingness to work toward a