Counsel Review Required Before Production
This production set is staged for your review. Before sending to Connell Foley LLP:
- Verify no privileged documents are included (attorney-client, work product, litigation strategy)
- Confirm the scope matches Plaintiff's responses dated March 14, 2026
- Review the Admissions Inventory (REQ8) — decide if this is work product or producible
- The email CSVs (REQ4) contain metadata only, not full message bodies — confirm this is sufficient
- Consider whether a privilege log is needed per CPLR 3122(b)