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Saturday, July 10, 2021 5:34:11 PM
narrow the range of issues addressed in Plaintiffs’ motion. In addition to resolving entirely Plaintiffs’
argument regarding waiver of the attorney-client privilege, the parties have had continued discussions
about the deliberative process privilege issues raised in Plaintiffs’ motion. Recently, Treasury produced
additional documents that it had previously withheld pursuant to the deliberative process privilege, and
the parties continue to engage in a meet-and-confer process that has the potential to further narrow the
issues in dispute. The additional time requested in this motion will allow this process to continue while
also affording Defendants time to prepare a response to issues raised in Plaintiffs’ motion that the parties
are unable to resolve through their negotiations."
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