Dwight K. Keller (0074533),
Assistant United States Attorney, Dayton, Ohio, Trial Attorney for Plaintiff
United States of America.
Sasha Alexa M. VanDeGrift
(0080800), COOLIDGE WALL CO., L.P.A., Dayton, OH, Trial Attorney for Defendant
AGREED PROTECTIVE ORDER CLARIFYING SCOPE OF THE LIMITED PRIVILEGE AND WORK PRODUCT WAIVERS
MICHAEL R. MERZ, Magistrate Judge.
On Motion of the United States to interview Jill R. Flagg, Esq. (Doc. No. 184), former counsel for Defendant Gregory Chew, and with the agreement of Chew's present counsel in this matter, the Court enters the following Agreed Order to allow Ms. Flagg to discuss her prior representation of Mr. Chew.
The Government and Mr. Chew hereby agree that the scope of Mr. Chew's waiver of his attorney-client and work-product privileges is limited to the following issues as set forth in said Motion to Vacate:
Ms. Flagg's allegedly inadequate review and introduction of documents relevant to the defense of Mr. Chew;
Ms. Flagg's alleged lack of a meaningful investigation of the case;
Ms. Flagg's alleged overall unpreparedness at trial;
Ms. Flagg's allegedly ill-conceived and generic defense of Mr. Chew;
Ms. Flagg's decision not to present expert witness testimony/evidence on behalf of Mr. Chew;
Ms. Flagg's decision not to present fact witness testimony on behalf of Mr. Chew;
Ms. Flagg's purported failure to properly subpoena and call witnesses on behalf of Mr. Chew even though she had obtained Court approval to do so;
Ms. Flagg's allegedly ineffective cross-examination and failure to elicit appropriate testimony from ...