Extract to table

The moving party must demonstrate that the discovery sought is relevant to any party's claim or defense and proportional to the needs of the case

This burden requires more than conclusory assertions; Helios must provide sufficient factual detail to enable the requesting party and the Court to assess the validity of the privilege claim for each document

3d at 1149 (privilege log must provide "sufficient information to enable the court and opposing counsel to evaluate" the privilege claim); Ruiz v