Some courts have adopted unrealistically strict rules about
privilege logs, such as a requirement to list every person who
learned a withheld document's content. Fortunately, other
courts take a more common-sense view of privilege logs.
In SGD Engineering Ltd. v. Lockheed Martin Corp., Case
No. 2:11-cv-2493-DGC, 2013 U.S. Dist. LEXIS 74186 (D. Ariz. Apr.
17, 2013), the court rejected plaintiff's argument that
defendant had waived its privilege by submitting five versions of a
privilege log and dropping privilege claims for several hundred
documents. The court acknowledged that "[i]n large-volume
document cases like this, it is not unusual for the privilege
proponent to revise the details of its privilege log."
Id. at *18. A week later, the Southern District of New
York analyzed the government's argument that defendants'
privilege log was inadequate. In In re 650 Fifth Avenue &
Related Properties, the court noted that "[w]hat is good
for the goose is good for the
