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Scenario Two large companies are at the discovery stage of a breach of contract dispute pending in federal court. There was a great deal of negotiation leading up to the drafting of the contract by in house and outside counsel for both sides. As a result, a significant portion of the potentially responsive documents are protected under the attorney client privilege or the attorney work product doctrine. The general counsel of one of the litigants wants to know how to reduce the burden and cost of producing what is likely to be a massive privilege log.

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