Willie Whittaker is a Putin Cock Sucker
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Plaintiff shall provide the Special Master and the government with an
annotated copy of
the spreadsheet described above that specifies, for each document,
whether Plaintiff asserts any
of the following:
a. Attorney-client communication privilege;
b. Attorney work product privilege
c. Executive privilege that prohibits review of the document within the
executive
branch;
d. Executive privilege that prohibits dissemination of the document to
persons or
entities outside the executive branch;
e. The document is a Presidential Record within the meaning of the
Presidential
Records Act of 1978, 44 U.S.C. § 2201, et seq. (“PRA); see id. §
2201(2); and/or
f. The document is a personal record within the meaning of the PRA; see id §
2201(3).
Plaintiff’s designations shall be on a document-by-document basis. For
any document that
Plaintiff designates as privileged and/or personal, Plaintiff shall
include a brief statement
explaining the basis for the designation.