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Case No.04CW217 <br /> Summit County's 26(a)(1)Disclosures <br /> Page 7 of 9 <br /> 11. Any exhibit offered for the purposes of rebuttal. <br /> 12. The documents identified in the disclosure statements of the Applicant, and any of <br /> the opposers. <br /> 13. Any document not listed that is relevant to matters not alleged with specificity in <br /> the application. <br /> To the extent not already provided,the above documents are available for inspection and <br /> copying at a reasonable cost by prior arrangement with Summit County's undersigned counsel. <br /> C. Description of cate g or i es of damages: <br /> g es: <br /> Not applicable. <br /> D. Insurance Agreements: <br /> Not applicable. <br /> E. Assertion of privilege pursuant to Rule 26(b)(5): <br /> Summit County asserts,pursuant to Rule 26(b)(5),that the following categories of <br /> documents are privileged and/or subject to protection as trial preparation material: <br /> 1. Confidential letters,memos or other communications from Summit County's <br /> counsel to Summit County's representatives and from Summit County's representatives to <br /> Summit County's counsel. Such communications were prepared in anticipation of litigation or in <br /> furtherance of the interests of Summit County in this litigation and/or other related matters, and, <br /> as such, are privileged attorney-client communications and/or attorney work product. <br /> 2. Letters,notes,research,memorandum,legal analysis, and other documents <br /> (including drafts thereof)prepared by Summit County's counsel,in anticipation and furtherance <br /> of Summit County's interests in this litigation and/or other related matters. Such documents <br /> constitute attorney work product. <br /> __ .._ - 3. Copies of documents,otherwise made available through disclosure, which copies <br /> bear notes of counsel which were prepared in contemplation of liti atiori or whicli were prepared - - <br /> p p p g P P ---- <br /> in contemplation of litigation or which were intended to be used in furtherance of Summit <br /> County's interests in this litigation and/or other related matters. <br /> 4. Confidential letters,memoranda and other correspondence from any expert <br /> consultants to Summit County and its counsel prepared in anticipation of litigation or in <br />