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In most cases the subpoenas were so broad —-
they were broad enough they’d asked for the ethics
folders, so I wasn’t going through the ethics folder to
determine if Document A, B, C was responsive, because
the entire folder was called for. I would look through
it, Bates stamp it, index it, whatever you needed to
do.

If the subpoena called for all reports
written on Tuesday, he might —- a client may very well
provide with you every report, the lawyer might go
through and determine what’s responsive and provide it.
But there was no —- but most of these subpoenas are so
broad in that they called for everything, but they were
reviewed.

issues a subpoena for an ethics folder, would it not be
a responsibility to turn that over and not decide
‘what’s important to give them? Or am I confused on the
issue?

subpoena called for the ethics folder, the lawyers
‘provided that. Lawyers didn’t cull through the ethics
folder and pull anything, determine whether something
was responsive or useful, we just made the sure the
documents matched up with the subpoenas.