FILED: NEW YORK COUNTY CLERK 10/20/ :11 PM INDEX NO /2013 NYSCEF DOC. NO. 148 RECEIVED NYSCEF: 10/20/2015

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1 FILED: NEW YORK COUNTY CLERK 10/20/ :11 PM INDEX NO /2013 NYSCEF DOC. NO. 148 RECEIVED NYSCEF: 10/20/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X KRISTINA M. ARMSTRONG, v. Plaintiff, Index No /2013 PLAINTIFF S REVISED PRIVILEGE LOG FOR SUCCESSOR COUNSEL S FILES BLANK ROME LLP, NORMAN S. HELLER, DYLAN S. MITCHELL, Defendants X Plaintiff Kristina Armstrong, respectfully attaches hereto, her Revised Privilege Log for Successor Counsel s files. 1. Initials on Privilege Log: Plaintiff KA=Kristina Armstrong The Firm of Kramer Kozek, LLP KK=Kramer Kozek, LLP and all attorneys and staff GK=Georgia D. Kramer, Esq. NK=Neil E. Kozek, Esq. DS=Deborah Sherman, Esq. CC=Cathy Credendino, Paralegal The Firm of Hennessey & Bienstock LLP HB=Hennessey & Bienstock LLP, and all attorneys and staff PH=Patricia Hennessey, Esq. PB=Peter Bienstock, Esq. The Consulting Firm of Eisner Amper, LLC, as experts MB=Martin Blaustien, CPA

2 2. Michael means R. Michael Armstrong, Plaintiff s former husband. 3. Family Court Matters The litigated matters arising near, on or after the Settlement Agreement was signed on May 11, 2011 and/or the Judgment of Divorce was entered on August 5, 2011, such as physical abuse, bugging of Plaintiff s cell phone or other acts by Michael Armstrong committed against Plaintiff, alleged Defaults or breaches of the Settlement Agreement or other Post- Judgment matters, purely personal issues, for example, children custody issues, parenting plans, holidays, health records, and/or alleged non-compliance with certain terms of the Settlement Agreement. 4. Matrimonial Case The underlying divorce action, known as Armstrong v. Armstrong, Supreme Court, Westchester County, Index No , up to the entry of the Judgment of Divorce, August 5, Produced relates to documents that were initially marked or separated as privileged, but upon review, have been produced. 6. Relates to a different client, inadvertently in boxes refers to documents and attorneys notes relating to their other clients that were inadvertently mixed in the Armstrong boxes. Dated: New York, New York October 20, 2015 Respectfully submitted, SACK & SACK, LLP By: /s/_eric R. Stern Eric R. Stern, Esq. Attorneys for Plaintiff 110 East 59th Street, 19th Floor New York, New York Tel.: (212) Fax: (212)

3 Revised Log of Attorney-Client, Attorney-Work Product and/or Family Court/Post Judgment Materials from Successor Counsel's Files Bates # Date From To Subject Doc type /2011 KA DS and GK Family Court Matters s, subpoena, cell phone tacking device put on phone by Michael, etc /19/2011 KA DS Family Court Matters Questions re hearing re Michael's abuse 14 Produced /12/2011 GK and PH Family Court Matters s and handwritten notes re abuse hearing/medical records Produced Produced /26/2011 KK KA Family Court Matters Re Subpoena served for abuse hearing 192 Produced /28/2011 TT KA Family Court Matters Alleged Default Notice re non-financial issues Produced Produced 204 5/24/2011 CC KC Attorney-client billing matters Produced 227 1/2/2011 GK, KA KA, GK withdrawals and Xmas holiday Produced /23/2011 DS KA Family Court matters w/draft bill of particulars, police report Produced /9/2009 KA GH Unrelated damage caused by neighbor to personal property Produced KA GK or PH Family/children issues cell phone statement with notes Produced /25/2011 KA DS Family Court Matters Michael's abuse/police Report Produced /7/2009 Unrelated damage caused by neighbor to personal property Produced /4/2011 GK Medical Records Plaintiff's personal medical records Produced 439 4/30/2011 GK Medical Records Plaintiff's personal medical records /29/2011 KA GK and PH trial/hearing prep P's Notes to Atty's on family dynamics Produced Produced Produced /27/2011 KA GK and PH Children issues s 837 Produced 838 6/15/2011 Family court matters Michael's Chart of world events /7/2011 GK or PH Interoffice/client billing matters s w/ attachments Produced KA GK or PH Family Court matters Notes regarding Michael's physical abuse /23/2015 GK search terms for document search Produced /20/2010 GK Children issues handwritten attorney notes re client meeting Produced 948 1/2/2011 KA GK and PH Michael's sabatoge of X-mas Produced /17/2011 PH Children issues Client meeting notes with KA and GK Produced PH or GK notes re family issues in dispute handwritten attorney notes Produced KA PH notes re family issues in dispute handwritten attonrney notes

4 Produced Produced PH Notes re Family matters handwritten attorney notes 1146 Produced PH Notes re Family matters handwritten attorney notes 1175 Produced /16/2010 HB PH Billing arrangement/opening file KA GK and PH Family Court Matters-testimony memorandum Produced KA GK and PH Notes & materials re family memorandum /6/2009 KA Repairs to House+neighor issues Invoices and letters Produced Produced /24/2010 KA GK and PH Personal issues re family matters s Produced /8/2010 KA, GK, PH KA, GK, PH Personal, Michael's Paramour s Produced /15/2010 PH, KA PH, KA parenting time s /16/2011 PH, GK PH, GK Matrimonial Case s Produced /17/2010 PH, GK PH, GK Matrimonial Case s with attachments Produced missing /2010 KA, GK, PH KA, GK,PH Thanksgiving Plans/children s Produced KA, GK, PH KA, GK,PH Weekends and Parenting Plans s /2011 KA, GK, PH KA, GK,PH potential meeting & trial dates s Produced /2011 KA, GK, PH KA, GK,PH Chrildren Issues, Incidents s Produced /2011 KA, GK, PH KA, GK,PH Harrassment & Personal Issues s Produced KA GK, PH Personal issues re family matters Produced KA, GK, PH KA, GK,PH Personal issues re family matters s Produced KA GK, PH Verbal Harrassment with memo Produced KA GK, PH Saftey of Children /1/2011 KA, GK,PH KA, GK,PH Children Schedules s Produced /8/2011 KA PH Parenting Schedule Produced /15/2011 KA, GK GK, KA Personal note Rye art show s Produced /19/2011 PH GK Michael's Paramour Produced /26/2011 KA GK, PH Personal Background materials , with memorandum Produced /26/2011 KA GK, PH Personal Background materials , with memorandum Produced /2/2011 KA GK, PH Court appearance Produced /4/2011 KA GK, PH Weekend and Saftey

5 Produced Produced KA GK, PH Children Summer studies Materials /25/2013 KA GK, PH Family Court matters /27/2012 KA GK, PH Family Court matters/defaults Produced /11/2011 KA GK, PH Family Court matters/defaults and Notice of Default Produced /25/2011 GK KA Billing matters with attachment Produced /27/2011 KA, PH PH, KA Billing matters s Produced /25/2011 KA, PH PH, KA Billing matters s Produced /27/2011 KA, PH PH, KA Billing matters s Produced /25/2011 KA, PH PH, KA Billing matters Produced /2011 KA, PH, GK PH, KA, GK Protect. Order/Michael at house s and memorandum Produced KA, PH, GK PH, KA, GK Post-Settl. Agreement Defaults s Produced KA PH, GK Personal issues re family matters handwritten notes Produced /15/2010 KA, PH, GK PH, KA, GK Custody and Parenting time s and materials Produced /6/2010 KA, PH, GK PH, KA, GK Custody and Parenting time s Produced /13/2011 KA GK and PH Children and related issues Notes Produced PH Relates to a different client,inadvertently in boxes KA PH Children and related issues Notes PH Relates to a different client,inadvertently in boxes /8/2011 KA PH Parenting Schedule PH Relates to a different client,inadvertently in boxes Produced PH Relates to a different client,inadvertently in boxes Produced PH Relates to a different client,inadvertently in boxes Produced PH Relates to a different client,inadvertently in boxes Produced /8/2010 KA GK Michael's Physical Abuse Police Report Produced /16/2011 KK KA Billing matters Statement Produced /10/2011 KK PH, GK Joint Decision Making children and notes Produced /23/2013 KA CC Escrow Account /2013 KA, CC KA, CC Status of physical files s GK, PH, KA GK, PH, KA Post-Judgment Defaults s and materials Produced /2011 KA, GK, PH KA, GK, PH Division of Per. Possessions s Produced