Def. Ex. A · Document · Anderson v. Nexora Corp.
Memo from in-house counsel on recall timing. Inadvertently produced; defendant asserts attorney-client privilege and seeks clawback.
Received in production
Aisha Kim · Bates NEX-031900
Clawback asserted
Daniel Whitman (opposing) · Privilege claw-back letter received; sequestered pending ruling
Internal counsel memo — recall strategy
DOC-011223