Cori Rigsby - Insurance Coverage Blog

Rigsby_Cori_-_Vol _II.txt19 It's a letter dated October 15, 2007.20 It's a multi-page letter that goes through each of21 the items.22 MR. ROBIE:23 It doesn't break down any document by24 document.25 MR. TAYLOR:02701 No, of course not.2 MR. MEHTA:3 No. But what it does do is identify the4 Bates range of documents that --5 MR. ROBIE:6 Hundreds of pages of documents for which7 a privilege is asserted, without breaking them8 down.9 MR. MEHTA:10 Are you talking about privileged11 documents or are you talking about documents that12 were actually produced?13 MR. ROBIE:14 I'm talking about the claimed privileged15 documents.16 MR. TAYLOR:17 No, no. This letter identifies by Bates18 number the documents that are produced.19 MR. MEHTA:20 And to that letter, we attached a21 privilege log which identified documents that are22 Bates range numbered.23 MR. ROBIE:24 My point is -- and I really don't want25 to waste my record here with this because the02711 document will speak for itself, but the privilege2 log is a Bates range of many hundreds of pages of3 material with a claimed privilege. It doesn't4 break it down by document.5 MR. MEHTA:6 Well, that's not exactly accurate, but7 you're right, the document will speak for itself.8 We did produce attachments. There are basically9 five documents or six documents that we withheld10 for various reasons. We have produced almost all11 of that with the exception, I think, of documents12 that fell within Categories 5 and 6, which are13 currently subject to a motion to compel before14 Judge Walker.15 MR. ROBIE:16 Q. Do your duties as part of your contract17 with -- first of all, is the contract with18 Mr. Scruggs, the Scruggs Law Firm or the Scruggs19 Katrina Group?20 A. The Scruggs Katrina Group.21 Q. And who comprises the Scruggs Katrina22 Group, as you know it?23 A. Dick's office -- Dick Scruggs' office in24 Oxford, Don Barrett's office and Nutt McAllister25 in Jackson, and I think there's Lovelace.02721 Q. How about Mike Moore?2 A. And Mike Moore.3 Q. Did it ever include Johnny Jones, JonesPage 16