United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
APPENDIX A
Privilege Doc. Date Description Ruling Log No. 2 1 8/9/2001- E-mail chain with KBR counsel regarding guaranty Privileged and/or work product. 8/13/2001 agreement for LOGCAP proposal. 2 12 10/1/2007 Document from KBR Law Department regarding Not privileged or protected. document preservation directive and possible employee Litigation hold notice not intended interviews. to be confidential and not attorney work product. 2 13 4/29/2008 E-mail from Bill Utt and counsel to all KBR employees Not privileged or protected. regarding document preservation directive for all Litigation hold notice not intended activities under LOGCAP III and outside inquiries. to be confidential and not attorney work product. 2 14 5/25/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel relating to D&P B-6 Man Camp dispute. 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 Not privileged or protected. Only advice from corporate counsel relating to D&P B-6 Man reflects that consultation with Camp dispute. [Redacted and produced as attorney occurred, not the KBR-BARKO-018116-018119] substance of the communication.
1 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 2 17 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as incidental recipient. For other KBR-BARKO-018326-018331] 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 Privileged and/or work product. receiving legal advice about D&P B-6 Man Camp dispute and DCAA audit. 2 19 1/31/2006 E-mail to corporate counsel for purposes of receiving Privileged and/or work product. legal advice about D&P B-6 Man Camp dispute and DCAA audit. 2 20 1/4/2006 Memorandum produced at request of corporate counsel in Privileged and/or work product. order to obtain legal advice concerning EAMAR contract termination. 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 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 2 23 1/7/2003 Redacted e-mail chain seeking and providing legal advice Redacted portion is privileged from corporate counsel concerning corporate registration and/or work product. in Jordan and the agentrelationship with D&P. [Redacted and produced as KBR-BARKO-35697-35700]
2 24 8/27/2004 Redacted e-mail conveying legal communications and Redacted portion is privileged requests for information from outside counsel at Vinson and/or work product. & Elkins. [Redacted and produced as KBR-BARKO- 035716-035717] 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 Not privileged or protected, except advice and conveying information to counsel for the for the email on page 3 of the purpose of obtaining legal advice about EAMAR contract document from Michael Hatch termination. [Redacted and produced as dated May 4, 2004. That email KBR-BARKO-035720-035721] may be redacted as it is a privileged communication from an attorney. The rest are communications where attorneys were mere incidental recipients.
3 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 2 27 7/28/2004 E-mails among counsel and KBR investigator and Redacted portion is privileged security personnel acting at direction of counsel regarding and/or work product. allegations in the e-mail produced at KBR-BARKO-032706-10 to be considered as part of internal investigation CBC-KBR-2004-002148. 2 28 1/20/2003 E-mail chain seeking and discussing legal advice from Privileged and/or work product corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 29 1/14/2003 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 30 3/13/2005 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 31 1/17/2003 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship.
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Privilege Doc. Date Description Ruling Log No. 2 32 1/14/2003 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 33 1/20/2003 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Peter Arbour concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 34 1/13/2003 E-mail chain seeking legal advice from corporate counsel Privileged and/or work product. Chris Heinrich concerning corporate registration in Jordan and D&P sponsor-agent relationship. 2 35 1/16/2003 Form prepared at direction and with assistance of Privileged and/or work product. corporate counsel for review by corporate counsel Chris Heinrich of D&P sponsor-agent relationship in Jordan.
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Privilege Doc. Date Description Ruling Log No. 2 36 1/13/2003 E-mail chain seeking and obtaining legal advice from Partially privileged. The two corporate counsel Chris Heinrich and Peter Arbour emails on page 1 of the concerning corporate registration in Jordan and D&P document—from Bill Courtney sponsor-agent relationship. 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 Redacted portion is privileged corporate counsel concerning EAMAR employees in Iraq. and/or work product. [Redacted and produced as KBRBARKO-E000351] 3 2 4/26/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship.
6 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 3 5/25/2004 E-mail chain seeking and receiving legal advice from Privileged and/or work product. corporate counsel concerning D&P B-6 Man Camp dispute. 3 4 6/6/2004 E-mail seeking legal advice from corporate counsel Privileged and/or work product. Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 7 4/19/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E024697] 3 8 4/19/2004 Redacted e-mail containing legal advice from corporate Redacted portion is privileged counsel related to EAMAR contract termination. and/or work product. [Redacted and produced as KBR-BARKO-E024703] 3 9 4/19/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E024709.]
7 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 10 5/3/2004 Redacted e-mail chain requesting and discussing legal Not privileged or protected. For advice from corporate counsel relating to D&P B-6 Man some parts, attorney only an Camp dispute. [Redacted and produced as incidental recipient. For other KBR-BARKO-E004777] 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 Privileged and/or work product. counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 12 8/19/2004 E-mail chain containing document preservation directive Not privileged or protected. in # 6 above with additional legal advice from corporate Litigation hold notice not intended counsel. to be confidential and not attorney work product. 3 15 10/3/2004 Redacted e-mail conveying legal advice from corporate Not privileged or protected. Any counsel Michael Hatch regarding investigation into D&P communications with attorney not employee treatment. [Redacted and produced as for purpose of seeking or providing KBR-BARKO-E024874] legal advice. 3 17 3/27/2004 E-mail chain concerning investigation and seeking legal Redacted portion is privileged advice from corporate counsel concerning EAMAR and/or work product. termination. [Redacted and produced as KBR-BARKO-36812]
8 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 18 8/19/2004 E-mail chain containing document preservation directive Not privileged or protected. from Andy Lane and corporate counsel for all activities Litigation hold notice not intended under LOGCAP III and outside inquiries. to be confidential and not attorney work product. 3 20 5/4/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as incidental recipient. For other KBR-BARKOE005522] 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 Privileged and/or work product. legal advice about EAMAR contract termination. 3 22 7/6/2004 E-mail chain seeking and obtaining legal advice about Privileged and/or work product. corporate registration in Jordan and discussing scheduling COBC training in Jordan. 3 23 6/9/2004 E-mail chain seeking legal advice from corporate counsel Not privileged or protected. Only concerning EAMAR employees in Iraq. [Redacted and reflects that consultation with produced as KBR-BARKO-036816] attorney occurred, not the substance of the communication.
9 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 24 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E005747] 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 Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E025227] parts, only reflects that consultation with attorney occurred, not the substance of the communication.
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Privilege Doc. Date Description Ruling Log No. 3 26 4/7/2004 E-mail sent to corporate counsel discussing legal advice Not privileged or protected, except from corporate counsel Chris Heinrich about EAMAR for three sentences in the first contract termination. [Redacted and produced as paragraph of the email on page 1 of KBR-BARKO-E02533] 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 Privileged and/or work product. D&P B-6 Man Camp dispute. 3 28 5/8/2004 E-mail to corporate counsel seeking legal advice about Privileged and/or work product. D&P B-6 Man Camp dispute. 3 29 5/8/2004 Draft notice document related to D&P B-6 Man Camp Privileged and/or work product. dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #28 above).
11 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 30 5/6/2004 Draft notice document related to D&P B-6 Man Camp Privileged and/or work product. dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #28 above). 3 31 7/6/2004 E-mail chain seeking and obtaining legal advice about Privileged and/or work product. corporate registration in Jordan. 3 32 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E006496] 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 Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E025440] 3 35 8/6/2004 E-mail containing document preservation directive from Not privileged or protected. Andy Lane and corporate counsel for all activities under Litigation hold notice not intended LOGCAP III and outside inquiries. to be confidential and not attorney work product.
12 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 36 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E006876] 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 Not privileged or protected. Only from corporate counsel relating to D&P B-6 Man Camp reflects that consultation with dispute. [Redacted and produced as KBR- attorney occurred, not the BARKO-E025960] substance of the communication. 3 38 6/1/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 44 7/4/2004 Redacted e-mail chain seeking legal advice from Redacted portion is privileged corporate counsel concerning EAMAR employees in Iraq. and/or work product. [Redacted and produced as KBR-BARKO-E001500] 3 45 7/5/2004 Redacted e-mail chain seeking legal advice from Redacted portion is privileged corporate counsel concerning EAMAR employees in Iraq. and/or work product. [Redacted and produced as KBRBARKO-E030965]
13 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 46 4/16/2004 E-mail chain seeking and containing legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 47 11/22/2004 Statement provided to KBR investigator as part of Code Privileged and/or work product. of Business Conduct investigation conducted at the direction of corporate counsel. 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 Privileged and/or work product. corporate counsel concerning D&P B-6 Man Camp dispute. 3 51 7/26/2004 Redacted e-mail chain containing legal advice from Redacted portion is privileged corporate counsel concerning corporate registration in and/or work product. Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030970] 3 52 5/24/2004 E-mail chain seeking and containing legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship.
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Privilege Doc. Date Description Ruling Log No. 3 53 5/16/2004 E-mail to corporate counsel seeking legal advice about Privileged and/or work product. D&P B-6 Man Camp dispute. 3 54 5/16/2004 Draft notice document related to D&P B-6 Man Camp Privileged and/or work product. dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #53 above). 3 55 4/7/2004 E-mail seeking legal advice from corporate counsel Privileged and/or work product. concerning EAMAR termination. 3 56 5/5/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E008621] 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 Not privileged or protected. Only Michael Hatch relating to Heston and D&P water well reflects that consultation with contracts. [Redacted and produced as KBR-BARKO- attorney occurred, not the E017577] substance of the communication.
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Privilege Doc. Date Description Ruling Log No. 3 58 8/19/2004 E-mail chain containing document preservation directive Not privileged or protected. from Andy Lane and corporate counsel for all activities Litigation hold notice not intended under LOGCAP III and outside inquiries. to be confidential and not attorney work product. 3 60 5/29/2004 E-mail seeking legal advice from corporate counsel Privileged and/or work product. concerning D&P B-6 Man Camp dispute. 3 61 5/8/2004 Draft D&P B-6 Man Camp termination for convenience Privileged and/or work product. letter prepared by George Covelli sent to corporate counsel Michael Hatch for legal review (attached to #60 above). 3 62 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E008905] 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 Privileged and/or work product. corporate registration in Jordan and discussing scheduling COBC training in Jordan.
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Privilege Doc. Date Description Ruling Log No. 3 65 4/19/2004 Duplicate of #7, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E027482] and/or work product. 3 66 4/19/2004 Duplicate of #7, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E027508] and/or work product. 3 70 5/4/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E009645] 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 Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKO- incidental recipient. For other E009701] 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 Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028011]
17 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 74 7/5/2004 Duplicate of #1, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E009778] and/or work product. 3 75 6/9/2004 Duplicate of #23, above. [Redacted and produced as Not privileged or protected. Only KBR-BARKO-E002416] 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 Privileged and/or work product. concerning D&P B-6 Man Camp dispute. 3 77 5/3/2004 Redacted e-mail chain requesting legal advice from Not privileged or protected. For corporate counsel relating to D&P B-6 Man Camp some parts, attorney only an dispute. [Redacted and produced as KBR-BARKOE- incidental recipient. For other 010087] 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 Not privileged or protected. Only KBR-BARKO-E028203] reflects that consultation with attorney occurred, not the substance of the communication.
18 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 79 5/6/2004 Redacted e-mail to corporate counsel seeking legal advice Redacted portion is privileged relating to the EAMAR contract termination. [Redacted and/or work product. and produced as KBR-BARKO-E028220] 3 80 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028223] 3 81 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028260] 3 82 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028263] 3 83 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028268.]
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Privilege Doc. Date Description Ruling Log No. 3 84 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028227] 3 85 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028229] 3 86 5/2/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028271] 3 87 5/2/2004 Duplicate of #83, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E028273.] and/or work product. 3 88 5/1/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E028277]
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Privilege Doc. Date Description Ruling Log No. 3 89 4/24/2004 E-mail sent to corporate counsel discussing legal advice Not privileged or protected. from the corporate counsel about payments to EAMAR. Attorney only an incidental recipient. 3 90 4/21/2004 Redacted e-mail seeking legal advice from corporate Redacted portion is privileged counsel related to EAMAR contract termination. and/or work product. [Redacted and produced as KBR-BARKO-E028282] 3 91 4/19/2004 Redacted e-mail chain seeking and containing legal Redacted portion is privileged advice from corporate counsel related to EAMAR and/or work product. contract termination. [Redacted and produced as KBR-BARKO-E028286] 3 92 4/19/2004 Duplicate of #7, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E028289] and/or work product. 3 93 4/19/2004 Duplicate of #9, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E028295] 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 Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship.
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Privilege Doc. Date Description Ruling Log No. 3 96 5/25/2004 E-mail chain giving legal advice from corporate counsel Privileged and/or work product. concerning D&P B-6 Man Camp dispute. 3 97 5/25/2004 E-mail chain seeking and receiving legal advice from Privileged and/or work product. corporate counsel concerning D&P B-6 Man Camp dispute. 3 98 Summary of cure notice review by corporate counsel Privileged and/or work product. Michael Hatch containing legal advice about D&P B-6 Man Camp dispute. 3 99 4/26/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 100 5/23/2004 Draft stop-work order related to D&P B-6 Man Camp Privileged and/or work product. dispute prepared by George Covelli sent to Michael Hatch for legal review (attached to KBR-BARKO-036809). 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.
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Privilege Doc. Date Description Ruling Log No. 3 104 11/24/2004 E-mail among counsel and KBR investigator acting at Privileged and/or work product. direction of counsel in response to Code of Business Conduct hotline reports and status of internal investigation as directed. 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 Not privileged or protected. corporate counsel for all activities under LOGCAP III and Litigation hold notice not intended outside inquiries. Duplicate of #19, above. to be confidential and not attorney work product. 3 107 5/24/2004 E-mail chain seeking and containing legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 108 6/11/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship.
23 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 109 5/3/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel related to EAMAR contract and/or work product. termination. [Redacted and produced as KBR-BARKO-E029184] 3 110 4/7/2004 E-mail seeking and obtaining legal advice from corporate Privileged and/or work product. counsel concerning EAMAR termination. 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 Not privileged or protected. from Randy Harl and corporate counsel for all activities Litigation hold notice not intended under LOGCAP III and outside inquiries. to be confidential and not attorney work product. 3 114 8/19/2004 E-mail containing document preservation directive from Not privileged or protected. Andy Lane and corporate counsel for all activities under Litigation hold notice not intended LOGCAP III and outside inquiries, including additional to be confidential and not attorney instructions from Chris Heinrich. work product. 3 115 8/2/2004 E-mail chain containing document preservation directive Not privileged or protected. from Randy Harl and corporate counsel for all activities Litigation hold notice not intended under LOGCAP III and outside inquiries. to be confidential and not attorney work product.
24 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 116 5/13/2004 E-mail containing document reservation directive from Not privileged or protected. Randy Harl and corporate counsel for all activities under Litigation hold notice not intended LOGCAP III and outside inquiries. to be confidential and not attorney work product. 3 117 9/14/2004 E-mail containing document preservation directive from Not privileged or protected. Andy Lane and corporate counsel for all activities under Litigation hold notice not intended LOGCAP III and outside inquiries. to be confidential and not attorney work product. 3 118 3/18/2005 E-mail to corporate counsel seeking legal advice related Privileged and/or work product. to D&P B-6 Man Camp termination. 3 119 Memo sent to corporate counsel for the purpose of Privileged and/or work product. obtaining legal advice regarding potential partial termination for default of D&P on B6 Man Camp (attached to #118 above). 3 120 4/9/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship.
25 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 121 4/7/2004 E-mail sent to corporate counsel discussing legal advice Not privileged or protected, except from corporate counsel Chris Heinrich about EAMAR for three sentences in the first contract termination. [Redacted and produced as paragraph of the email on page 1 of KBR-BARKO-036842] 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 Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 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 Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship.
26 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 125 Duplicate of #98 above. Privileged and/or work product. 3 126 7/22/2004 Redacted e-mail chain seeking and obtaining legal advice Redacted portion is privileged from corporate counsel relating to subcontractor dispute and/or work product. with EAMAR and Drilco. [Redacted and produced as KBR-BARKO-E029895] 3 127 6/10/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Kuwait and Jordan and D&P sponsor-agent relationship. 3 128 6/5/2004 E-mail chain seeking and receiving legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan, D&P sponsor-agent relationship, and D&P B-6 Man Camp dispute. 3 129 7/26/2004 Redacted e-mail providing legal advice from corporate Redacted portion is privileged counsel concerning corporate registration in Jordan and and/or work product. D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030982]
27 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 130 4/9/2004 E-mail seeking legal advice from corporate counsel Chris Privileged and/or work product. Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 131 4/19/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 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 Not privileged or protected. Only counsel relating to Heston and D&P water well contracts. reflects that consultation with [Redacted and produced as KBR-BARKO-E032911] attorney occurred, not the substance of the communication. 3 134 9/17/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 135 4/8/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 136 4/15/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
28 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 137 4/16/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 138 4/22/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 139 4/23/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 140 4/29/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 141 4/30/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 142 8/6/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 143 8/12/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 144 8/13/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 145 8/27/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
29 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 146 12/15/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 147 2/4/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 148 2/11/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 149 2/18/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 150 2/28/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 151 1/14/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 152 1/21/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 153 1/28/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 154 7/1/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
30 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 155 7/8/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 156 7/9/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 157 7/16/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 158 7/23/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 159 7/30/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 160 6/3/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 161 6/4/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 162 6/10/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 163 6/11/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
31 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 164 6/17/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 165 6/17/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 166 6/24/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 167 3/4/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 168 3/11/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 169 3/18/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 170 3/25/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 171 5/6/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 172 5/7/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
32 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 173 5/13/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 174 5/14/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 175 5/20/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 176 5/21/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 177 5/27/2005 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 178 5/28/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 179 11/12/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 180 1/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 181 10/1/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues.
33 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 182 10/15/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 183 10/31/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 184 3/29/2004 E-mail seeking and obtaining legal advice from corporate Redacted portion is privileged counsel concerning EAMAR termination. [Redacted and and/or work product. produced as KBR-BARKO-036848] 3 185 4/17/2004 Redacted e-mail seeking and obtaining legal advice from Redacted portion is privileged corporate counsel concerning corporate registration in and/or work product. Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E030985] 3 186 6/27/2006 E-mail from security investigator acting at direction and Privileged and/or work product. 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. 3 187 6/7/2006 Draft statement from security investigator acting at Privileged and/or work product. direction and under supervision of counsel to employee (attached to #284 above).
34 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 188 7/16/2004 Weekly report by corporate counsel on his investigations, Privileged and/or work product. litigation preparation, and contract issues. 3 189 5/29/2004 E-mail seeking legal advice from corporate counsel Privileged and/or work product. concerning D&P B-6 Man Camp dispute. 3 190 5/28/2004 Draft termination for convenience related to D&P B-6 Privileged and/or work product. Man Camp dispute prepared by George Covelli sent to corporate counsel Michael Hatch for legal review. 3 191 7/15/2004 Redacted e-mail chain containing legal advice from Redacted portion is privileged corporate counsel concerning corporate registration in and/or work product. Jordan and D&P sponsor-agent relationship. [Redacted and produced as KBR-BARKO-E031008] 3 192 3/18/2005 Duplicate of #118, above. Privileged and/or work product. 3 193 Memo from Clif Taylor to Michael Hatch describing Privileged and/or work product. partial termination for default of D&P on B6 Man Camp attached to e-mail to counsel. 3 194 5/25/2004 Duplicate of #97, above. Privileged and/or work product. 3 195 Duplicate of #98 above. Privileged and/or work product.
35 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 196 3/29/2004 E-mail chain concerning investigation and seeking legal Redacted portion is privileged advice from corporate counsel concerning EAMAR and/or work product. termination. [Redacted and produced as KBR-BARKO-36852] 3 197 4/21/2004 Redacted e-mail seeking legal advice from corporate Redacted portion is privileged counsel related to EAMAR contract termination. and/or work product. [Redacted and produced as KBR-BARKO-E030596.] 3 198 4/12/2004 E-mail chain seeking and obtaining legal advice from Privileged and/or work product. corporate counsel Chris Heinrich and Michael Hatch concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 201 6/5/2004 E-mail chain seeking and receiving legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan, D&P sponsor-agent relationship, and D&P B-6 Man Camp dispute. 3 202 5/25/2004 E-mail chain involving Michael Hatch offering legal Privileged and/or work product. advice relating to D&P subcontract dispute. Duplicate of #97, above. 3 203 4/13/2004 E-mail chain between corporate counsel concerning Privileged and/or work product. corporate registration in Jordan.
36 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 204 4/1/2004 E-mail chain seeking and containing legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship. 3 205 2/28/2005 Redacted e-mail from corporate counsel providing legal Redacted portion is privileged advice concerning EAMAR contract termination. and/or work product. [Redacted and produced as KBR-BARKOE-051571] 3 206 4/19/2004 Duplicate of #8, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E052342] and/or work product. 3 207 4/19/2004 Duplicate of #7, above. [Redacted and produced as Redacted portion is privileged KBR-BARKO-E053570] and/or work product. 3 208 4/19/2004 Redacted e-mail chain to and from corporate counsel Redacted portion is privileged providing legal advice concerning EAMAR contract and/or work product. termination. Duplicate of #9, above.[Redacted and produced as KBR-BARKO-E056165] 3 209 6/2/2004 Redacted e-mail chain seeking legal advice from Not privileged or protected. Only corporate counsel concerning D&P B-6 Man Camp reflects that consultation with dispute. [Redacted and produced as KBR- attorney occurred, not the BARKO-E048069] substance of the communication.
37 United States ex rel. Barko v. Halliburton Co., No. 1:05-cv-1276
Privilege Doc. Date Description Ruling Log No. 3 210 5/24/2004 E-mail chain seeking and containing legal advice from Privileged and/or work product. corporate counsel concerning corporate registration in Jordan and D&P sponsor-agent relationship.