Professional Documents
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E-FILED
As but one particularly egregious example, the USAO baselessly insinuates that the reason Mr. Schock withdrew
his assertion of privilege as to three documents was because the government has requested documents from third
parties identified in the privilege log. As this Court is aware from Mr. Schocks ex parte filing, the privilege claim
was withdrawn for a technical legal reason, not because of any attempt by the USAO to obtain documents
elsewhere. Moreover, as the USAO is well aware, there are 11 other documents involving the same third party for
which Mr. Schock is still maintaining privilege. Thus, it defies logic for the USAO to claim that Mr. Schock has
withdrawn his privilege claim on three documents involving a particular third party from whom the USAO has said
it is seeking documents but not the other 11 involving that same third party.
3:15-mc-03005-SEM # 96
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We respectfully submit, however, that additional briefing is unnecessary for the Court to
conduct its in camera review of the documents provided by Mr. Schock.
Respectfully submitted,
3:15-mc-03005-SEM # 96
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CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing instrument was electronically filed with the
Clerk of the Court using the CM/ECF system, which will send notification of such filing to
counsel of record at their respective email addresses disclosed on the pleadings on this 7th day of
October 2015.