Replies to post #300953 on Fannie Mae-No Politics (FNMA)

[Dollars1]

Interesting! Thanks Blushing Green!

[Dollars1]

Here's the first page!
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO REMOVE THE “PROTECTED INFORMATION” DESIGNATION FROM DEFENDANT’S PROVISIONAL PRIVILEGE LOGS The Court should deny the motion by Fairholme Funds, Inc. (Fairholme) to remove the “Protected Information” designation from provisional privilege logs produced by the United States.1 The provisional privilege logs contain confidential information meeting the definition of “Protected Information” under the protective order. Moreover, the provisional logs represent the Government’s preliminary judgments about privilege claims and were provided to plaintiffs as an accommodation and in the interests of expediting the discovery process. The logs have changed from week to week as the Government continues reviewing documents initially identified as potentially privileged. Thus, many of the entries are now obsolete and inaccurate. Fairholme cannot articulate any legitimate, litigation-related rationale for the relief it seeks where (1) Fairholme counsel has access to the provisional logs under the protective order, and (2) the Government intends to produce a public version of the final privilege log. There is no legitimate justification or proper purpose for permitting Fairholme to publicize provisional logs containing preliminary and now obsolete information. For these reasons, Fairholme’s motion is not only without merit, but is also a waste of the Court’s and the parties’ time. 1 Fairholme identifies the March 20, 2015 provisional log in its motion, but states that it expects the Court’s ruling to apply to subsequent provisional logs. Pls. Mot. at 2 n.2.