Travelers Property Casualty Company of America v. Bobrick Washroom Equipment, Inc.

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
TRAVELERS PROPERTY
CASUALTY COMPANY OF
AMERICA,
Plaintiff,
v.
BOBRICK WASHROOM
EQUIPMENT, INC.,
Defendant.
CIVIL ACTION NO. 3:18-CV-0094
(SAPORITO, J.)
MEMORANDUM
On October 25, 2017, Travelers Property Casualty Company of
America 	(“Travelers”) 	filed 	this 	action 	against 	Bobrick 	Washroom
Equipment, Inc. (“Bobrick”) in the U.S. District Court for the Central
District of California seeking to recoup approximately $7,300,000 in
counsel fees and costs associated with
Scranton Products, Inc. v. Bobrick
Washroom 	Equipment 	Inc., 	No. 	3:14-CV-00853 	(M.D. 	Pa.) 	(the
“underlying action”). (Doc. 1). But over eight years later, including a
transfer 	to 	the 	U.S. 	District 	Court 	for 	the 	Middle 	District 	of
Pennsylvania, this case has yet to be fully litigated on its merits.
On September 27, 2018, in response to a document request from
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 1 of 18

- 2 -
Bobrick, Travelers inadvertently disclosed alleged privileged materials.
On November 15, 2018, Bobrick filed a letter informing the court about
the inadvertent production issue, as well as Bobrick’s position that the
production of those documents by Travelers resulted in a waiver of
privilege under Federal Rules of Evidence 502(b). In a November 19,
2018, response to Bobrick’s letter, Travelers argued to the court that its
inadvertent production of documents did not waive the privilege because
its 	legal 	counsel 	took 	reasonable 	steps 	to 	prevent 	the 	inadvertent
production under Rule 502(b)(2).1 Nonetheless, since that response on
November 19, 2018, the issue of whether Travelers waived privilege of
those documents remained unresolved.2
On 	September 	8, 	2025, 	Bobrick 	informed 	the 	court 	that 	an
evidentiary hearing would be necessary to resolve the issue of whether
1 	The 	issue 	of 	whether 	privilege 	is 	waived 	in 	an 	inadvertent
disclosure of documents is governed by Rule 502(b) of the Federal Rules
of Evidence.
2 	On November 1, 2024, Bobrick filed a motion to compel the
production 	of 	the 	inadvertently 	disclosed 	documents, 	arguing 	that
Travelers waived any attorney-client and work product privileges by
putting those communications “at issue” in a defense in this action. (Doc.
176). On July 17, 2017, we denied Bobrick’s motion on the basis that
merely invoking the protections of Rule 502(b) of the Federal Rules of
Evidence does not put those protected communications “at issue” for
purposes of a waiver. (Doc. 201).
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 2 of 18

- 3 -
Travelers waived its privilege of those documents that were inadvertently
produced to Bobrick on September 27, 2018. (Doc. 208). On September
11, 2025, Travelers argued that an evidentiary hearing was unnecessary
to 	determine 	the 	issue 	of 	waiver 	of 	privilege. 	(Doc. 	209). 	After
consideration 	of each 	party’s 	position, 	we 	scheduled 	an 	evidentiary
hearing on November 6, 2025, to conclusively determine the issue of
whether 	Travelers 	waived 	its 	privilege 	through 	the 	inadvertent
disclosure of documents. (Doc. 216). The hearing was conducted over a
period of two days on November 6, 2025, and November 18, 2025,
consisting of eighty-six exhibits and testimony from seven witnesses.
Both parties have submitted briefs regarding the inadvertent disclosure
issue (Doc. 243; Doc. 244) and the matter is now ripe for review.
I. 	Legal Standard
The Federal Rules of Civil Procedure allow parties to “obtain
discovery regarding any nonprivileged matter that is relevant to any
party’s claim or defense.” Fed. R. Civ. P. 26(b)(1). There are two types of
privilege. 	The 	attorney-client 	privilege 	“protects 	from 	disclosure
confidential communications made between attorneys and clients for the
purpose of obtaining or providing legal assistance to the client.”
In re
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 3 of 18

- 4 -
Grand Jury Subpoena, 745 F.3d 681, 687 (3d Cir. 2014) (internal citation
omitted). The work-product privilege protects “tangible things that are
prepared in anticipation of litigation or for trial by or for another party
or its representatives (including the other party’s attorney, consultant,
surety, indemnitor, insurer, or agent).” Fed. R. Civ. P. 26(b)(3).
An attorney may waive privilege while acting on behalf of his client.
See 	Westinghouse, 	951 	F.2d 	at 	1420, 	1431 	(waiving 	attorney-client
privilege as to documents provided to a third party by attorneys at behest
of 	a 	client). 	When 	an 	attorney 	inadvertently 	discloses 	privileged
communications, they become subject to the possibility of waiver.
See
Fed. R. Civ. P. 502(b);
Fid. & Deposit Co. of Maryland v. McCulloch, 168
F.R.D. 516, 523 (E.D. Pa. 1996) (“[W]hile the attorney-client privilege
belongs to the client, the attorney, acting as the client’s agent, may be
sufficiently negligent in protecting the privilege that it may be waived”);
Maldonado v. New Jersey ex rel. Admin. Office of Courts-Prob. Div., 225
F.R.D. 120, 128 (D.N.J. 2004) (discussing “the doctrine of waiver of the
attorney-client privilege resulting from the inadvertent disclosure by an
attorney”).
Rule 502 of the Federal Rules of Evidence governs waiver of
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 4 of 18

- 5 -
attorney-client 	privilege 	or 	work-product 	protection. 	Rule 	502(a)
addresses intentional waiver, such as where “a party intentionally puts
protected information into the litigation in a selection, misleading and
unfair manner.” Expl. Note to Fed. R. Evid. 502. Rule 502(b) deals with
inadvertent 	disclosures 	of 	privileged 	materials, 	instructing 	that 	a
disclosure does not operate as a waiver in a federal or state proceeding if:
“(1) the disclosure is inadvertent; (2) the holder of the privilege or
protection took reasonable steps to prevent disclosure; and (3) the holder
promptly 	took 	reasonable 	steps 	to 	rectify 	the 	error, 	including 	(if
applicable) following Federal Rule of Civil Procedure 26(b)(5)(B).” Fed. R.
Evid. 502(b). When determining whether a party waived privilege in an
inadvertent disclosure, district courts in the Third Circuit have weighed
the following five factors:
(1) the reasonableness of the precautions taken to
prevent inadvertent disclosure in view of the extent
of 	the 	document 	productions; 	(2) 	the 	number 	of
inadvertent 	disclosures; 	(3) 	the 	extent 	of 	the
disclosure; 	(4) 	any 	delay 	and 	measures 	taken 	to
rectify the disclosure; and (5) whether the overriding
interests of justice would or would not be serviced by
relieving the party of its errors.
In re Niaspan Antitrust Litig., No. 13-MD-2460, 2017 WL 3668907, at *2
(E.D. Pa. Aug. 24, 2017) (citing
Ciba-Geigy Corp. v. Sandoz Ltd., 916 F.
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 5 of 18

- 6 -
Supp. 404, 411 (D.N.J. 1995)).
II. 	Discussion
The issue of whether a party has waived privilege under Rule 502(b)
of the Federal Rules of Evidence appears to be a narrow one generally,
see Fed. R. Evid. 502(b)
, but in this action, the issue is even more narrow.
Bobrick has conceded two of the elements: (1) that the disclosure was
inadvertent and (3) that Travelers promptly took reasonable steps to
rectify the error. (Doc. 243, at 13) (“There is no dispute over Rule 502(b)’s
first and third prongs.”); The sole issue before the Court is whether
Travelers took reasonable steps under the second element to prevent the
inadvertent disclosure of documents under Rule 502(b)(2) of the Federal
Rules of Evidence.
A. Mr. Peterson’s Original November 19, 2018 Letter
On November 19, 2018, Mark Peterson, then-counsel for Travelers,
wrote the Court a letter detailing how the inadvertent disclosure of
privileged documents occurred and how Travelers had taken reasonable
steps to prevent that inadvertent disclosure. (Doc. 61).3 Mr. Peterson
3 All information contained in this subsection is taken from that
letter. (Doc. 61).
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 6 of 18

- 7 -
explained that Travelers enlisted the help of Epiq Global (“Epiq”), a
worldwide legal service vendor providing administrative support for
eDiscovery services, to handle its discovery request and contracted with
Epiq because:
Epiq is one of the largest resellers of Relativity, which is
one of the most widely used software platforms for the
review 	and 	production 	of 	electronically 	stored
information. 	Epiq 	has 	been 	performing 	hosting 	and
document review services for Travelers since 2014. Epiq
has handled more than 200 matters for Travelers across
the country and elsewhere.
Moreover, Mr. Peterson had previously worked with Epiq in two other
cases and found Epiq to be “highly capable and reliable.”
At some point, Mr. Peterson provided Epiq with Bobrick’s requested
documents 	and 	asked 	Epiq 	to 	perform 	e-mail 	threading 	and
deduplication services on those documents.4 Mr. Peterson explained that
4 “Threading” and “deduplication” services are aimed to greatly
reduce 	the 	time 	and 	complexity 	of 	reviewing 	documents. 	The
deduplication process removes duplicate files in a document set so that a
lawyer may review only one of those files, rather than each additional
duplicate files as well.
See (Doc. 230, at 7) (“[I]f you have the same email
five times, after deduplication, you would only have to review one of the
documents. It helps to make the review go quicker.”). The threading
process 	combines 	multiple 	email 	chains 	into 	a 	single, 	organized
conversation 	so 	that 	an 	individual 	sees 	the 	entire 	history 	of 	the
conversation in one document, rather than across multiple documents.
(continued on next page)
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 7 of 18

- 8 -
those 	services 	produced 	numerous 	redundant 	and 	deduplicated
documents that were subsequently moved into an administrative folder.
This folder was neither accessible nor visible to Travelers, only to Epiq.
Mr. Peterson stated that he personally reviewed the remaining
12,000 documents for privilege and work-product protection over a period
of twenty-five hours. He articulated that he did not delegate any of this
work to any other lawyer. He explained that when he finished reviewing
those 	documents 	and 	added 	redactions 	to 	preserve 	privilege, 	Epiq
numbered 	the 	pages 	and 	published 	the 	redacted 	documents 	for
production to his firm and to counsel for Bobrick. But unknown to Mr.
Peterson, 	Epiq 	had 	mistakenly 	added 	the 	previously 	segregated
deduplicated and redundant documents into the final folder with Mr.
Peterson’s previously reviewed documents. Therefore, when Travelers
produced those documents to Bobrick, it produced those that were both
reviewed and unreviewed for privilege.
Mr. 	Peterson, 	in 	that 	letter, 	concluded 	that 	Travelers 	took
See (
id.) (“[E]mail threading is … another choice to load the emails into
the review platform where you end up with … the latest thread of that
conversation … so you’re not having to review multiple pieces of the email
chain separately.”).
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 8 of 18

- 9 -
reasonable 	steps 	to 	protect 	the 	inadvertent 	disclosure 	because 	he
personally 	reviewed 	all 	12,000 	documents 	for 	privilege 	that 	were
available to him, and he reasonably relied on a prominent eDiscovery
firm to help with the discovery requests.
B. 	The November 6, 2025, and November 18, 2025, Hearings
Almost 	seven 	years 	after 	Mr. 	Peterson’s 	letter, 	we 	scheduled
evidentiary hearings on November 6, 2025, and November 18, 2025, to
conclusively 	determine 	the 	issue 	of 	whether 	Travelers 	waived 	its
privilege through the inadvertent disclosure of documents.5 The evidence
in those hearings not only expanded upon the details included within Mr.
Peterson’s letter but also substantiated many of his claims. We have
outlined the facts in the paragraph below.
Travelers filed this action in 2017 against Bobrick seeking to recoup
approximately $7,300,000 in counsel fees and costs associated with the
case,
Scranton Products, Inc. v. Bobrick Washroom Equipment, Inc., No.
3:14-CV-00853 (M.D. Pa.). (Doc. 1). As part of the discovery process, on
July 16, 2018, Bobrick requested documents from Travelers concerning
Travelers’s claims to the settlement proceeds from the underlying action.
5 This action was reassigned to the undersigned on October 8, 2024.
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 9 of 18

- 10 -
See plaintiff ’s exhibit (Doc. 1). Travelers subsequently enlisted Epiq to
help process Bobrick’s discovery request.
See plaintiff ’s exhibit (Doc. 2).
Natalia (Majewski) Stachowski6 was assigned as Epiq’s primary project
manager to help with Travelers’s services.
See plaintiff ’s exhibit (Doc. 2).
Travelers subsequently provided Epiq with Bobrick’s requested
documents to upload and store on the Relativity software platform.
See
plaintiff ’s exhibit (Doc. 3). At the direction of Mr. Peterson, Travelers
asked Epiq to perform e-mail threading and deduplication services of
those 	documents. 	(
Id.). 	On 	September 	17, 	2018, 	Mrs. 	Stachowski
informed Travelers that Epiq had applied those processes and provided
Travelers with the updated data file.
	See plaintiff ’s exhibit (Doc. 4).
However, unbeknownst to Travelers, the threading and deduplication
services resulted in 611 redundant documents that were placed in a
separate administrator folder only visible to Epiq.
See (Doc. 230, at 18)
(“[T]he 611 documents … were in a secured and locked folder that only
Epiq could see and Cates Peterson could not see.”).
6 At the time of the underlying events, Natalia’s last name was
“Majewski,” and she is referred to as “Natalia Majewski” in all exhibits.
Since the underlying events, however, Natalia has changed her last name
from “Majewski” to “Stachowski” because of her marriage.
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 10 of 18

- 11 -
After receiving the updated document data set, Mr. Peterson began
to review those documents for privilege and work product protection. He
testified consistent with his letter to the court that he “personally
reviewed 	the 	documents 	… 	[and] 	personally 	redacted 	them 	and 	[]
personally coded them as privileged where appropriate.” (Doc. 61, at 2).
Early in that process, however, Mr. Peterson found that he had to
manually label each individual document as “responsive” to examine it
for privileged material. Thereafter, he asked Mrs. Stachowski to mass
code all the documents as “responsive” after confirming that doing so
would not affect his previous progress.
See plaintiff ’s exhibit (Doc. 5). On
September 18, 2025, Mrs. Stachowski informed Mr. Peterson that she
had completed the “responsive” mass coding. (
Id.).
After 	spending 	approximately 	twenty-five 	hours 	reviewing 	the
“responsive” data set for privilege, Mr. Peterson directed Epiq to number
the pages and publish the redacted document for production to his firm.
(Doc. 61, at 2). On September 26, 2018, before producing the data set,
Mrs. Stachowski notified Mr. Peterson and Rachel Ayers, a paralegal for
the 	law 	firm 	Cates 	Peterson, 	that 	there 	were 	around 	six 	hundred
documents in the data set that had not been coded “responsive.”
See
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 11 of 18

- 12 -
plaintiff ’s exhibit (Doc. 7). Mr. Peterson testified that he believed that
those documents in the data set had already been reviewed for privilege
because he had just spent twenty-five hours analyzing the entire data
set. Therefore, Ms. Ayers asked Mrs. Stachowski to mark them as
“responsive” 	and 	to 	produce 	the 	data 	set.
	See 	(
id.). 	However,
unbeknownst to Mr. Peterson, Ms. Ayers, and even Mrs. Stachowski,
those 611 documents belonged to the group of redundant documents that
were previously placed in a separate administrator folder because of the
threading and deduplication processes. Mrs. Stachowski admitted that
she had accidentally added those previously separated documents into
the reviewed data set.
On September 27, 2018, Travelers provided the data set to Bobrick.
See plaintiff ’s exhibit (Doc. 8). On October 18, 2018, Bobrick, through
counsel, notified Travelers that it had encountered apparently privileged
documents within that data set after a preliminary review thereof.
See
plaintiff ’s exhibit 	(Doc. 	9). 	On 	October 19, 	2018, 	Travelers notified
Bobrick that the disclosure of documents was inadvertent.
See plaintiff ’s
exhibit (Doc. 10). Throughout the following days, Mr. Peterson and Epiq
investigated how the inadvertent disclosure occurred throughout the
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 12 of 18

- 13 -
discovery process, reaching the conclusion that the deduplicated and
threaded documents were accidentally re-added to the production data
set.
See plaintiff ’s exhibits (Docs. 10―18). On October 29, 2018, Travelers
produced an updated data set to Bobrick without the inadvertently
disclosed 611 documents.
See plaintiff ’s exhibit (Doc. 16).
C. 	Travelers Did Not Waive Privilege
In light of this background, Bobrick argues that “[t]he evidentiary
record 	demonstrates 	that 	Travelers 	systematically 	failed 	to 	protect
privileged information.” (Doc. 243, at 5). Indeed, Bobrick suggests that
Travelers made no efforts at all to protect that information. (
Id., at 18)
(quoting
Amobi v. District of Columbia Dep’t of Corr., 262 F.R.D. 45, 55
(D.D.C. 2009)) (“There can be no reasonable efforts, unless there are
efforts in the first place.”). But the record shows that Travelers undertook
many steps to protect the inadvertently disclosed documents.
Travelers enlisted the help of Epiq to process Bobrick’s discovery
request.
See plaintiff ’s exhibit (Doc. 2). As courts in this District have
emphasized, “eDiscovery vendors are an increasingly common tool used
in the management of high volume ESI discovery.”
Lawson v. Love’s
Travel 	Stops 	& 	Country 	Stores, 	Inc., 	No. 	1:17-CV-1266, 	2019 	WL
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 13 of 18

- 14 -
5622453, at *5 (M.D. Pa. Oct. 31, 2019) (citing
Race Tires Am., Inc. v.
Hoosier Racing Tire Copr., 674 F.3d 158, 159 (3d Cir. 2012)). “Oftentimes,
such vendor services can provide an orderly means of securing, retaining,
reviewing 	and 	disclosing 	voluminous 	ESI.”
	Id. 	Travelers 	use 	of 	an
eDiscovery vendor constitutes a well-accepted and reasonable method to
handle its discovery process. But Travelers also enlisted Epiq specifically
to handle that process. Epiq is an eDiscovery vendor that resells “one of
the most widely used software platforms for the review and production of
electronically stored information.” (Doc. 61). Mr. Peterson also attested
that Epiq had performed over 200 matters for Travelers since 2014
without any issues.
Id.
As part of Travelers’s efforts to prevent the inadvertent disclosure,
Mr. Peterson and Ms. Ayers also directed Mrs. Stachowski to label all
documents 	as 	“responsive” 	so 	that 	Mr. 	Peterson 	could 	individually
analyze each document to determine privilege.
See plaintiff ’s exhibit
(Doc. 5). Mr. Peterson then reviewed each document personally over a
period of twenty-five hours.
See (Doc. 61, at 2). He explained that “[He]
reviewed the de-duplicated documents, approximately 12,000 pages…
[and] personally reviewed the documents for privilege, work product
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 14 of 18

- 15 -
protections 	etc.… 	I 	did 	not 	delegate 	this 	work.” 	(
Id.). 	None 	of 	the
witnesses, including Ms. Ayers, dispute Mr. Peterson’s testimony.
Travelers further provided Bobrick with the requested data set with
a 	password-protected 	link 	for 	Bobrick’s 	counsel 	to 	download 	the
documents to their system.
See plaintiff ’s exhibit (Doc. 8). Moreover,
Travelers sent Bobrick’s counsel the password-protected link and the
password for that link through two separate emails for extra security.
(
Id.). We find that these preventative measures, among others, constitute
reasonable steps to prevent the inadvertent disclosure of privileged
documents.
But Bobrick seemingly does not contest that those measures taken
by Travelers constitute reasonable steps. Instead, Bobrick’s argument
that Travelers waived privileged is entirely focused on Mr. Peterson’s
decision to mark the inadvertently added 611 documents as “responsive”
without reviewing those documents a
second time as a precautionary
measure. 	Bobrick 	argues 	that 	had 	Mr. 	Peterson 	reviewed 	those
documents, he would have discovered that they contained privileged
material, and therefore, Mr. Peterson acted unreasonably when deciding
not to review them again. But based on the evidence in the record, Mr.
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 15 of 18

- 16 -
Peterson’s decision not to review the documents a second time does not
constitute an unreasonable measure.
Mr. Peterson testified that when he directed Mrs. Stachowski to
mark the added-in 611 documents as “responsive,” he was under the
assumption that he had previously reviewed those 611 documents for
privilege. He believed that Mrs. Stachowski had simply failed to mark
them as “responsive” as she had done for the remaining previously
reviewed documents. Ms. Ayers testified to the same effect. Under the
totality of the circumstances, we find it reasonable that Mr. Peterson did
not review a document batch that he believed had already been reviewed.
Indeed, we reiterate that the standard for waiving privilege under Rule
502(b)(2) is whether Travelers took
	reasonable steps to prevent the
inadvertent disclosure; the standard is not whether Travelers took
every
step possible to prevent the disclosure.
	See Absolute Activist Value
Master Fund, Ltd v. Devine, 262 F. Supp. 3d 1312, 1325 (finding that
although “Defendant likely could have done more[,]” the defendant took
reasonable 	steps 	to 	prevent 	the 	inadvertent 	disclosure);
	Urban 	Air
Initiative, Inc. v. Envir. Protection Agency, 2017 WL 11589178, at *1
(D.D.C. June 23, 2017) (“[T]here is no requirement that a party must
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 16 of 18

- 17 -
utilize every possible method to protect against inadvertent disclosure.
Defendant must simply have taken reasonable steps.”). The mere fact
that Mr. Peterson could have reviewed the data set an additional time
does not inherently mean it was unreasonable for him to do so. Without
any evidence in the record to indicate that Mr. Peterson had a reason to
suspect 	that 	unreviewed 	privileged 	documents 	were 	added 	to 	the
reviewed data set, it cannot be said that Mr. Peterson was unreasonable
in deciding not to review those documents an additional time. We cannot
identify any of that evidence and Bobrick has failed to direct us to any of
it as well.
Indeed, after seven years of litigating the inadvertent disclosure
issue in this case, the conclusion is rather simple and unremarkable:
Epiq made a technical mistake in its discovery process that led to the
inadvertent disclosure despite reasonable steps taken by Travelers. Mrs.
Stachowski accidentally placed privileged documents, ones taken from an
administrative 	folder 	only 	accessible 	and 	visible 	to 	Epiq, 	into 	Mr.
Peterson’s data set for publication without anyone’s knowledge. Mrs.
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 17 of 18

- 18 -
Stachowski’s 	self-admitted 	mistake7 	occurred 	despite 	Travelers’s
reasonable 	steps 	to 	prevent 	the 	inadvertent 	disclosure 	rather 	than
because 	of 	Travelers’s 	steps 	to 	prevent 	that 	disclosure. 	Therefore,
Travelers did not waive privilege under Rule 502(b) of the Federal Rules
of Evidence.
III. 	Conclusion
For the foregoing reasons, Travelers did not waive attorney-client
privilege and work-product protection under Rule 502(b) of the Federal
Rules of Evidence.
An appropriate order follows.
Dated: January 14, 2026
	s/Joseph F. Saporito, Jr.
JOSEPH F. SAPORITO, JR.
United States District Judge
7 Mrs. Stachowski has admitted that her accidental actions led to
the 	inadvertent 	disclosure.
	See 	plaintiff ’s 	exhibit 	(Doc. 	14). 	Epiq
acknowledged the same.
See plaintiff ’s exhibit (Doc. 17, at 2).
Case 3:18-cv-00094-JFS-PJC Document 248 Filed 01/14/26 Page 18 of 18