BARKO v. HALLIBURTON COMPANY et al, No. 1:2005cv01276 - Document 204 (D.D.C. 2014)
Court Description: OPINION AND ORDER signed by Judge James S. Gwin on 11/20/14. The Court grants in part and denies in part KBR's motion for a protective order. This order will remain in effect unless modified or lifted by the Court. (Attachments: # 1 Privilege Log / Rulings) (Related Doc. 154 (Gwin, James)
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United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description Ruling 2 1 8/9/20018/13/2001 E-mail chain with KBR counsel regarding guaranty agreement for LOGCAP proposal. Privileged and/or work product. 2 12 10/1/2007 Document from KBR Law Department regarding document preservation directive and possible employee interviews. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 2 13 4/29/2008 E-mail from Bill Utt and counsel to all KBR employees regarding document preservation directive for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 2 14 5/25/2004 E-mail chain seeking and obtaining legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. Privileged and/or work product. 2 15 5/25/2004 Duplicate of #14 above. Privileged and/or work product. 2 16 6/2/2004 Redacted e-mail chain requesting and discussing legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKO-018116-018119] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 1 Dockets.Justia.com United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 2 17 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKO-018326-018331] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 2 18 2/10/2006 E-mail chain with corporate counsel requesting and receiving legal advice about D&P B-6 Man Camp dispute and DCAA audit. Privileged and/or work product. 2 19 1/31/2006 E-mail to corporate counsel for purposes of receiving legal advice about D&P B-6 Man Camp dispute and DCAA audit. Privileged and/or work product. 2 20 1/4/2006 Memorandum produced at request of corporate counsel in order to obtain legal advice concerning EAMAR contract termination. Privileged and/or work product. 2 21 1/4/2006 Duplicate of #20 above. Privileged and/or work product. 2 22 1/4/2006 Duplicate of #20 above. Privileged and/or work product. 2 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 2 23 1/7/2003 Redacted e-mail chain seeking and providing legal advice from corporate counsel concerning corporate registration in Jordan and the agentrelationship with D&P. [Redacted and produced as KBR-BARKO-35697-35700] Redacted portion is privileged and/or work product. 2 24 8/27/2004 Redacted e-mail conveying legal communications and requests for information from outside counsel at Vinson & Elkins. [Redacted and produced as KBR-BARKO035716-035717] Redacted portion is privileged and/or work product. 2 25 1/7/2003 Duplicate of #23 above. Redacted portion is privileged and/or work product. 2 26 5/4/2004 Redacted e-mail chain requesting and providing legal advice and conveying information to counsel for the purpose of obtaining legal advice about EAMAR contract termination. [Redacted and produced as KBR-BARKO-035720-035721] Not privileged or protected, except for the email on page 3 of the document from Michael Hatch dated May 4, 2004. That email may be redacted as it is a privileged communication from an attorney. The rest are communications where attorneys were mere incidental recipients. 3 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 2 27 7/28/2004 E-mails among counsel and KBR investigator and security personnel acting at direction of counsel regarding allegations in the e-mail produced at KBR-BARKO-032706-10 to be considered as part of internal investigation CBC-KBR-2004-002148. Redacted portion is privileged and/or work product. 2 28 1/20/2003 E-mail chain seeking and discussing legal advice from corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product 2 29 1/14/2003 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 2 30 3/13/2005 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 2 31 1/17/2003 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 4 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 2 32 1/14/2003 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 2 33 1/20/2003 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 2 34 1/13/2003 E-mail chain seeking legal advice from corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 2 35 1/16/2003 Form prepared at direction and with assistance of corporate counsel for review by corporate counsel Chris Heinrich of D&P sponsor-agent relationship in Jordan. Privileged and/or work product. 5 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 2 36 1/13/2003 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. Partially privileged. The two emails on page 1 of the document—from Bill Courtney dated January 13, 2003, and from Tod Nickles dated January 13, 2003—are not privileged or protected, as an attorney is only an incidental recipient, and in any event they do not seek or provide legal advice. The rest of the emails in the document are privileged communications that may be redacted. 3 1 7/5/2004 Redacted e-mail chain seeking legal advice from corporate counsel concerning EAMAR employees in Iraq. [Redacted and produced as KBRBARKO-E000351] Redacted portion is privileged and/or work product. 3 2 4/26/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 6 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 3 5/25/2004 E-mail chain seeking and receiving legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 4 6/6/2004 E-mail seeking legal advice from corporate counsel Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 7 4/19/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E024697] Redacted portion is privileged and/or work product. 3 8 4/19/2004 Redacted e-mail containing legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E024703] Redacted portion is privileged and/or work product. 3 9 4/19/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E024709.] Redacted portion is privileged and/or work product. 7 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 10 5/3/2004 Redacted e-mail chain requesting and discussing legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKO-E004777] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 11 6/6/2004 E-mail chain containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 12 8/19/2004 E-mail chain containing document preservation directive in # 6 above with additional legal advice from corporate counsel. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 15 10/3/2004 Redacted e-mail conveying legal advice from corporate counsel Michael Hatch regarding investigation into D&P employee treatment. [Redacted and produced as KBR-BARKO-E024874] Not privileged or protected. Any communications with attorney not for purpose of seeking or providing legal advice. 3 17 3/27/2004 E-mail chain concerning investigation and seeking legal advice from corporate counsel concerning EAMAR termination. [Redacted and produced as KBR-BARKO-36812] Redacted portion is privileged and/or work product. 8 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. 3 18 3 Date Description Ruling 8/19/2004 E-mail chain containing document preservation directive from Andy Lane and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 20 5/4/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE005522] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 21 4/7/2004 E-mail sent to corporate counsel for purposes of obtaining legal advice about EAMAR contract termination. Privileged and/or work product. 3 22 7/6/2004 E-mail chain seeking and obtaining legal advice about corporate registration in Jordan and discussing scheduling COBC training in Jordan. Privileged and/or work product. 3 23 6/9/2004 E-mail chain seeking legal advice from corporate counsel concerning EAMAR employees in Iraq. [Redacted and produced as KBR-BARKO-036816] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 9 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 24 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE005747] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 25 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE025227] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 10 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 26 4/7/2004 E-mail sent to corporate counsel discussing legal advice from corporate counsel Chris Heinrich about EAMAR contract termination. [Redacted and produced as KBR-BARKO-E02533] Not privileged or protected, except for three sentences in the first paragraph of the email on page 1 of the document from Larry Kosowski dated April 7, 2004. Of the five sentences in that paragraph, the first and last are not privileged or protected. The middle three sentences are privileged and therefore may be redacted. Otherwise, attorney is only an incidental recipient. 3 27 5/8/2004 E-mail to corporate counsel seeking legal advice about D&P B-6 Man Camp dispute. Privileged and/or work product. 3 28 5/8/2004 E-mail to corporate counsel seeking legal advice about D&P B-6 Man Camp dispute. Privileged and/or work product. 3 29 5/8/2004 Draft notice document related to D&P B-6 Man Camp dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #28 above). Privileged and/or work product. 11 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 30 5/6/2004 Draft notice document related to D&P B-6 Man Camp dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #28 above). Privileged and/or work product. 3 31 7/6/2004 E-mail chain seeking and obtaining legal advice about corporate registration in Jordan. Privileged and/or work product. 3 32 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE006496] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 33 4/7/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E025440] Redacted portion is privileged and/or work product. 3 35 8/6/2004 E-mail containing document preservation directive from Andy Lane and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 12 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 36 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE006876] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 37 6/2/2004 Redacted e-mail requesting and discussing legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBRBARKO-E025960] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 3 38 6/1/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 44 7/4/2004 Redacted e-mail chain seeking legal advice from corporate counsel concerning EAMAR employees in Iraq. [Redacted and produced as KBR-BARKO-E001500] Redacted portion is privileged and/or work product. 3 45 7/5/2004 Redacted e-mail chain seeking legal advice from corporate counsel concerning EAMAR employees in Iraq. [Redacted and produced as KBRBARKO-E030965] Redacted portion is privileged and/or work product. 13 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 46 4/16/2004 E-mail chain seeking and containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 47 11/22/2004 Statement provided to KBR investigator as part of Code of Business Conduct investigation conducted at the direction of corporate counsel. Privileged and/or work product. 3 48 5/8/2004 Duplicate of #28, above. Privileged and/or work product. 3 49 5/8/2004 Duplicate of #29, above. Privileged and/or work product. 3 49.1 5/6/2004 Duplicate of #30, above. Privileged and/or work product. 3 50 5/25/2004 E-mail chain seeking and receiving legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 51 7/26/2004 Redacted e-mail chain containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030970] Redacted portion is privileged and/or work product. 3 52 5/24/2004 E-mail chain seeking and containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 14 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 53 5/16/2004 E-mail to corporate counsel seeking legal advice about D&P B-6 Man Camp dispute. Privileged and/or work product. 3 54 5/16/2004 Draft notice document related to D&P B-6 Man Camp dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #53 above). Privileged and/or work product. 3 55 4/7/2004 E-mail seeking legal advice from corporate counsel concerning EAMAR termination. Privileged and/or work product. 3 56 5/5/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE008621] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 57 1/19/2005 Redacted e-mail legal advice from corporate counsel Michael Hatch relating to Heston and D&P water well contracts. [Redacted and produced as KBR-BARKOE017577] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 15 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. 3 58 3 Date Description Ruling 8/19/2004 E-mail chain containing document preservation directive from Andy Lane and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 60 5/29/2004 E-mail seeking legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 61 5/8/2004 Draft D&P B-6 Man Camp termination for convenience letter prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #60 above). Privileged and/or work product. 3 62 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE008905] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 64 7/6/2004 E-mail chain seeking and obtaining legal advice about corporate registration in Jordan and discussing scheduling COBC training in Jordan. Privileged and/or work product. 16 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 65 4/19/2004 Duplicate of #7, above. [Redacted and produced as KBR-BARKO-E027482] Redacted portion is privileged and/or work product. 3 66 4/19/2004 Duplicate of #7, above. [Redacted and produced as KBR-BARKO-E027508] Redacted portion is privileged and/or work product. 3 70 5/4/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE009645] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 72 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE009701] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 73 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028011] Redacted portion is privileged and/or work product. 17 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 74 7/5/2004 Duplicate of #1, above. [Redacted and produced as KBR-BARKO-E009778] Redacted portion is privileged and/or work product. 3 75 6/9/2004 Duplicate of #23, above. [Redacted and produced as KBR-BARKO-E002416] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 3 76 5/25/2004 E-mail giving legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 77 5/3/2004 Redacted e-mail chain requesting legal advice from corporate counsel relating to D&P B-6 Man Camp dispute. [Redacted and produced as KBR-BARKOE010087] Not privileged or protected. For some parts, attorney only an incidental recipient. For other parts, only reflects that consultation with attorney occurred, not the substance of the communication. 3 78 6/9/2004 Duplicate of #23, above. [Redacted and produced as KBR-BARKO-E028203] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 18 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 79 5/6/2004 Redacted e-mail to corporate counsel seeking legal advice relating to the EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028220] Redacted portion is privileged and/or work product. 3 80 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028223] Redacted portion is privileged and/or work product. 3 81 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028260] Redacted portion is privileged and/or work product. 3 82 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028263] Redacted portion is privileged and/or work product. 3 83 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028268.] Redacted portion is privileged and/or work product. 19 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 84 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028227] Redacted portion is privileged and/or work product. 3 85 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028229] Redacted portion is privileged and/or work product. 3 86 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028271] Redacted portion is privileged and/or work product. 3 87 5/2/2004 Duplicate of #83, above. [Redacted and produced as KBR-BARKO-E028273.] Redacted portion is privileged and/or work product. 3 88 5/1/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028277] Redacted portion is privileged and/or work product. 20 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 89 4/24/2004 E-mail sent to corporate counsel discussing legal advice from the corporate counsel about payments to EAMAR. Not privileged or protected. Attorney only an incidental recipient. 3 90 4/21/2004 Redacted e-mail seeking legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028282] Redacted portion is privileged and/or work product. 3 91 4/19/2004 Redacted e-mail chain seeking and containing legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E028286] Redacted portion is privileged and/or work product. 3 92 4/19/2004 Duplicate of #7, above. [Redacted and produced as KBR-BARKO-E028289] Redacted portion is privileged and/or work product. 3 93 4/19/2004 Duplicate of #9, above. [Redacted and produced as KBR-BARKO-E028295] Redacted portion is privileged and/or work product. 3 94 4/7/2004 Duplicate of #21, above. Redacted portion is privileged and/or work product. 3 95 4/10/2004 E-mail chain seeking and obtaining legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 21 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 96 5/25/2004 E-mail chain giving legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 97 5/25/2004 E-mail chain seeking and receiving legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 98 Summary of cure notice review by corporate counsel Michael Hatch containing legal advice about D&P B-6 Man Camp dispute. Privileged and/or work product. 3 99 4/26/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 100 5/23/2004 Draft stop-work order related to D&P B-6 Man Camp dispute prepared by George Covelli sent to Michael Hatch for legal review (attached to KBR-BARKO-036809). Privileged and/or work product. 3 101 11/22/2004 Duplicate of #47, above. Privileged and/or work product. 3 102 5/8/2004 Duplicate of #28 above. Privileged and/or work product. 3 103 5/8/2004 Duplicate of #29, above. Privileged and/or work product. 22 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 104 11/24/2004 E-mail among counsel and KBR investigator acting at direction of counsel in response to Code of Business Conduct hotline reports and status of internal investigation as directed. Privileged and/or work product. 3 105 8/19/2004 Duplicate of #58, above. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 106 8/2/2004 E-mail containing document preservation directive from corporate counsel for all activities under LOGCAP III and outside inquiries. Duplicate of #19, above. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 107 5/24/2004 E-mail chain seeking and containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 108 6/11/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 23 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 109 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E029184] Redacted portion is privileged and/or work product. 3 110 4/7/2004 E-mail seeking and obtaining legal advice from corporate counsel concerning EAMAR termination. Privileged and/or work product. 3 111 5/16/2004 Duplicate of #53, above. Privileged and/or work product. 3 112 5/16/2004 Duplicate of #54, above. Privileged and/or work product. 3 113 8/1/2004 E-mail chain containing document preservation directive from Randy Harl and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 114 8/19/2004 E-mail containing document preservation directive from Andy Lane and corporate counsel for all activities under LOGCAP III and outside inquiries, including additional instructions from Chris Heinrich. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 115 8/2/2004 E-mail chain containing document preservation directive from Randy Harl and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 24 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date 3 116 5/13/2004 E-mail containing document reservation directive from Randy Harl and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 117 9/14/2004 E-mail containing document preservation directive from Andy Lane and corporate counsel for all activities under LOGCAP III and outside inquiries. Not privileged or protected. Litigation hold notice not intended to be confidential and not attorney work product. 3 118 3/18/2005 E-mail to corporate counsel seeking legal advice related to D&P B-6 Man Camp termination. Privileged and/or work product. 3 119 Memo sent to corporate counsel for the purpose of obtaining legal advice regarding potential partial termination for default of D&P on B6 Man Camp (attached to #118 above). Privileged and/or work product. 3 120 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 4/9/2004 Description 25 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 121 4/7/2004 E-mail sent to corporate counsel discussing legal advice from corporate counsel Chris Heinrich about EAMAR contract termination. [Redacted and produced as KBR-BARKO-036842] Not privileged or protected, except for three sentences in the first paragraph of the email on page 1 of the document from Larry Kosowski dated April 7, 2004. Of the five sentences in that paragraph, the first and last are not privileged or protected. The middle three sentences are privileged and therefore may be redacted. Otherwise, attorney is only an incidental recipient. 3 122 4/12/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 123 5/25/2004 Duplicate of #50 above. Privileged and/or work product. 3 124 4/10/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 26 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. 3 125 3 126 3 Date Description Ruling Duplicate of #98 above. Privileged and/or work product. 7/22/2004 Redacted e-mail chain seeking and obtaining legal advice from corporate counsel relating to subcontractor dispute with EAMAR and Drilco. [Redacted and produced as KBR-BARKO-E029895] Redacted portion is privileged and/or work product. 127 6/10/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Kuwait and Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 128 6/5/2004 E-mail chain seeking and receiving legal advice from corporate counsel concerning corporate registration in Jordan, D&P sponsor-agent relationship, and D&P B-6 Man Camp dispute. Privileged and/or work product. 3 129 7/26/2004 Redacted e-mail providing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030982] Redacted portion is privileged and/or work product. 27 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 130 4/9/2004 E-mail seeking legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 131 4/19/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 132 5/25/2004 Duplicate of #3, above. Privileged and/or work product. 3 133 2/11/2005 Redacted e-mail containing legal advice from corporate counsel relating to Heston and D&P water well contracts. [Redacted and produced as KBR-BARKO-E032911] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 3 134 9/17/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 135 4/8/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 136 4/15/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 28 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 137 4/16/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 138 4/22/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 139 4/23/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 140 4/29/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 141 4/30/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 142 8/6/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 143 8/12/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 144 8/13/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 145 8/27/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 29 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 146 12/15/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 147 2/4/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 148 2/11/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 149 2/18/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 150 2/28/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 151 1/14/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 152 1/21/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 153 1/28/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 154 7/1/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 30 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 155 7/8/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 156 7/9/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 157 7/16/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 158 7/23/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 159 7/30/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 160 6/3/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 161 6/4/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 162 6/10/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 163 6/11/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 31 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 164 6/17/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 165 6/17/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 166 6/24/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 167 3/4/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 168 3/11/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 169 3/18/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 170 3/25/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 171 5/6/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 172 5/7/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 32 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 173 5/13/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 174 5/14/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 175 5/20/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 176 5/21/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 177 5/27/2005 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 178 5/28/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 179 11/12/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 180 1/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 181 10/1/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 33 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 182 10/15/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 183 10/31/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 184 3/29/2004 E-mail seeking and obtaining legal advice from corporate counsel concerning EAMAR termination. [Redacted and produced as KBR-BARKO-036848] Redacted portion is privileged and/or work product. 3 185 4/17/2004 Redacted e-mail seeking and obtaining legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030985] Redacted portion is privileged and/or work product. 3 186 6/27/2006 E-mail from security investigator acting at direction and under supervision of counsel to KBR employee to a KBR employee concerning internal investigation conducted at the direction of corporate counsel and forwarding a draft statement for the employee. Privileged and/or work product. 3 187 6/7/2006 Draft statement from security investigator acting at direction and under supervision of counsel to employee (attached to #284 above). Privileged and/or work product. 34 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date 3 188 7/16/2004 Weekly report by corporate counsel on his investigations, litigation preparation, and contract issues. Privileged and/or work product. 3 189 5/29/2004 E-mail seeking legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. Privileged and/or work product. 3 190 5/28/2004 Draft termination for convenience related to D&P B-6 Man Camp dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review. Privileged and/or work product. 3 191 7/15/2004 Redacted e-mail chain containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E031008] Redacted portion is privileged and/or work product. 3 192 3/18/2005 Duplicate of #118, above. Privileged and/or work product. 3 193 Memo from Clif Taylor to Michael Hatch describing partial termination for default of D&P on B6 Man Camp attached to e-mail to counsel. Privileged and/or work product. 3 194 Duplicate of #97, above. Privileged and/or work product. 3 195 Duplicate of #98 above. Privileged and/or work product. 5/25/2004 Description 35 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 196 3/29/2004 E-mail chain concerning investigation and seeking legal advice from corporate counsel concerning EAMAR termination. [Redacted and produced as KBR-BARKO-36852] Redacted portion is privileged and/or work product. 3 197 4/21/2004 Redacted e-mail seeking legal advice from corporate counsel related to EAMAR contract termination. [Redacted and produced as KBR-BARKO-E030596.] Redacted portion is privileged and/or work product. 3 198 4/12/2004 E-mail chain seeking and obtaining legal advice from corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 201 6/5/2004 E-mail chain seeking and receiving legal advice from corporate counsel concerning corporate registration in Jordan, D&P sponsor-agent relationship, and D&P B-6 Man Camp dispute. Privileged and/or work product. 3 202 5/25/2004 E-mail chain involving Michael Hatch offering legal advice relating to D&P subcontract dispute. Duplicate of #97, above. Privileged and/or work product. 3 203 4/13/2004 E-mail chain between corporate counsel concerning corporate registration in Jordan. Privileged and/or work product. 36 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. Date Description 3 204 4/1/2004 E-mail chain seeking and containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. Privileged and/or work product. 3 205 2/28/2005 Redacted e-mail from corporate counsel providing legal advice concerning EAMAR contract termination. [Redacted and produced as KBR-BARKOE-051571] Redacted portion is privileged and/or work product. 3 206 4/19/2004 Duplicate of #8, above. [Redacted and produced as KBR-BARKO-E052342] Redacted portion is privileged and/or work product. 3 207 4/19/2004 Duplicate of #7, above. [Redacted and produced as KBR-BARKO-E053570] Redacted portion is privileged and/or work product. 3 208 4/19/2004 Redacted e-mail chain to and from corporate counsel providing legal advice concerning EAMAR contract termination. Duplicate of #9, above.[Redacted and produced as KBR-BARKO-E056165] Redacted portion is privileged and/or work product. 3 209 6/2/2004 Redacted e-mail chain seeking legal advice from corporate counsel concerning D&P B-6 Man Camp dispute. [Redacted and produced as KBRBARKO-E048069] Not privileged or protected. Only reflects that consultation with attorney occurred, not the substance of the communication. 37 Ruling United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276 APPENDIX A Privilege Log Doc. No. 3 210 Date 5/24/2004 Description E-mail chain seeking and containing legal advice from corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. 38 Ruling Privileged and/or work product.
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