Extract to table

• The producing party shall provide prompt written notice to the receiving party upon discovery of any inadvertent production, identifying the affected documents by Bates number

• Upon receipt of such notice, the receiving party shall promptly return, sequester, or destroy all copies of the identified materials and shall not use or refer to such materials in any proceeding

Reviewers must exercise the same degree of care and diligence in identifying and protecting privileged materials as if no clawback agreement existed

Reviewers must become thoroughly familiar with these names and relationships

Reviewers must understand the elements, scope, and limitations of each category

These elements must be satisfied for each communication for which attorney-client privilege is claimed