Contract analysis

I. Status Report on the First Rolling Production We are pleased to confirm that the first rolling production of responsive documents was timely completed on January 20, 2023, in accordance with the negotiated extended return date. The first production consisted of 1,842 documents, Bates-stamped CALDWELL-00001 through CALDWELL-01842. All documents were produced in TIFF image format with accompanying load files contain

II. Description of Remaining Work and Anticipated Volume of Second Production The document review and privilege analysis for the remaining collected materials is ongoing and proceeding diligently. As we previously disclosed to your office, the collection phase yielded approximately 14,200 documents from all identified custodians and sources, encompassing approximately 8.3 gigabytes of data. The sources from which doc

III. Basis for the Extension Request The additional time requested is necessitated by the volume and complexity of the documents remaining under review, combined with the need for careful and methodical privilege analysis. As you are aware, the privilege review in this matter presents several areas of particular sensitivity: First, the collected materials include a significant number of communications between Mr. Cal

IV. Assurance of Good Faith and Continued Cooperation We wish to assure you that Mr. Caldwell continues to cooperate fully and in good faith with the grand jury's inquiry. He has instructed this firm to produce all responsive, non-privileged documents as promptly as practicable, and he has made himself available for consultation whenever questions have arisen during the review process regarding the source, context, o

V. Reservation of Rights Nothing in this letter, and nothing in the production of documents to date or hereafter, shall constitute or be deemed a waiver of any rights, objections, or defenses available to Mr. Caldwell, whether under the United States Constitution, the Federal Rules of Criminal Procedure, or any other applicable law or rule. Mr. Caldwell expressly reserves all rights and objections not previously and