Extract to table

Pinnacle's forensic review is ongoing, and all work product generated by Pinnacle at the direction of C&H must be treated as protected attorney work product

We must be vigilant in maintaining the distinction between underlying financial records (which are responsive and must be produced) and Pinnacle's analytical work product (which is privileged and must be withheld and logged)

• In reviewing documents in this category for production, we must consider whether any communications between Torchlight and its D&O insurer are protected by the attorney-client privilege

Any such communications that are in the company's possession may be responsive to the subpoena and must be produced unless separately privileged on other grounds

All Pinnacle work product must be carefully logged and its dissemination controlled

Privilege Log Requirements All documents withheld from production on the basis of attorney-client privilege or work product protection must be identified on a privilege log