Court filing
Exhibit 2 — In re Carvana Securities
Filed April 27, 2026 in In re Carvana Co Securities Litigation; one of 27 filings from this case.
Record facts
| Court | U.S. District Court for the District of Arizona |
|---|---|
| Filed | 2026-04-27 |
U.S. District Court for the District of Arizona · No. 2:22-cv-02126-MTL · Doc. 364-2 · 2026-04-27 · Docket on CourtListener
Full text
EXHIBIT 2 Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 1 of 12 1 Sarah Fallon From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Friday, August 1, 2025 5:30 PM To: Sarah Fallon; Rachel Cocalis; Tor Gronborg Cc: Ma, Charles; Blackshear, Afi Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Sarah, Thank you for this email. A few items/follow-ups in response: • For requests nos. 1-5, consistent with our R&O’s and discussions to date (including on Tuesday), Kirkland will collect and produce non-privileged and non-duplicative documents that are responsive to these requests. As discussed on our call on Tuesday, based upon our discussions with Latham, Carvana maintains that it has not put advice of counsel at issue (either through an affirmative defense or otherwise) and thus its position is that the privilege that exists between Carvana and Kirkland has not been waived. As discussed, this issue is something for Carvana and Plaintiffs to work out and/or resolve with the Court. Accordingly, until we hear otherwise from the Court or Carvana, Kirkland will maintain privilege. In terms of a search protocol, yes, as discussed, in order to produce non-privileged and non-duplicative responsive documents, we will prepare and disclose our search protocol. However, the timing to provide that by Tuesday will need to be revised. After our call on Tuesday, we reviewed the docket and note that there is still an outstanding dispute between the parties with respect to the applicable time period. We understand that a hearing on this issue is scheduled with the Court for August 11. Since any search protocol proposal we make will be impacted by the applicable time period, we will provide our proposal after the August 11 hearing (assuming the Court rules on the issue at the hearing) or after the Court rules on the issue following the August 11 hearing. • For request no. 6, as noted during our call on Tuesday, Kirkland maintains that the information called for in this request is not relevant and largely amounts to discovery on discovery. Nonetheless, in an effort to avoid further dispute and to resolve any issues on this request, Kirkland is willing to offer a compromise and produce a summary/list of (1) relevant timekeepers and (2) the total hours that each relevant timekeeper billed for the relevant work/for those matters during the relevant time period. Based on our call on Tuesday, we understand that Plaintiffs are amenable to this compromise. As noted above, we understand there to be a dispute between the parties with respect to the applicable time period and a hearing on that matter is scheduled with the Court for August 11. We will await a ruling from the court on that matter—at or after the August 11 hearing—to prepare the summary materials we are offering to produce. • For requests nos. 7-8, consistent with our discussion on Tuesday, Kirkland maintains and stands on its objections to these two requests. As discussed, Kirkland objects to these requests for numerous reasons, including that they are not relevant – in part because as discussed on our call on July 16, 2025, Plaintiffs are relying on potential bias to establish relevance for these requests, and we do not understand bias to be meaningfully at issue in this case. As discussed on our call on Tuesday, to the extent Plaintiffs intend to seek relief from the court regarding these two requests (now or in the future), please let us know in advance and we can confirm whether relevance is the sole outstanding objection. Thanks, Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 2 of 12 2 Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Sarah Fallon <SFallon@rgrdlaw.com> Sent: Thursday, July 31, 2025 2:27 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, Thank you so much for the call on Tuesday. We understand that, for requests 1-5, you will be putting together a list of search terms to produce non-privileged documents pursuant to these requests and, for request 6, you are willing Hi Kaitlin, Thank you so much for the call on Tuesday. We understand that, for requests 1-5, you will be putting together a list of search terms to produce non-privileged documents pursuant to these requests and, for request 6, you are willing to provide a list of timekeepers and the total hours each individual billed. We also understand that you maintain your objections to requests 7-8 based on relevance. We look forward to our call next Thursday to discuss your search term proposal. Thank you, Sarah From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Friday, July 25, 2025 12:03 PM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com>; Sarah Fallon <SFallon@rgrdlaw.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thank you, Rachel. Sounds good and talk to you all then. Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Friday, July 25, 2025 11:17 AM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com>; Sarah Fallon <SFallon@rgrdlaw.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, We are available on Tuesday at 11: 00 am PT/1: 00 pm ET. I will circulate a calendar invite. Thank you! Best, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Thursday, July 24, 2025 6: 46 AM To: Rachel Cocalis Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 3 of 12 3 Hi Kaitlin, We are available on Tuesday at 11:00 am PT/1:00 pm ET. I will circulate a calendar invite. Thank you! Best, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Thursday, July 24, 2025 6:46 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com>; Sarah Fallon <SFallon@rgrdlaw.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thank you so much. I am available: • Tuesday (7/29)—any time between noon-5 pm ET • Wednesday (7/30)—any time between noon-4 pm ET • Thursday (7/31)—any time between noon-3:30 pm ET Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Thursday, July 24, 2025 9:39 AM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com>; Sarah Fallon <SFallon@rgrdlaw.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena No problem. Please send us your availability. Best, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Thursday, July 24, 2025 6: 37 AM To: Rachel Cocalis <RCocalis@ rgrdlaw. com>; Tor Gronborg <TorG@ rgrdlaw. com> No problem. Please send us your availability. Best, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Thursday, July 24, 2025 6:37 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Tor and Rachel, Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 4 of 12 4 Would it be possible to move our M&C to sometime next week? I apologize for the request, but I had a change in my schedule, and I am now going to be on a plane during the time period we were supposed to speak later this afternoon. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Wednesday, July 9, 2025 12:08 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Great, thanks. From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Wednesday, July 9, 2025 9: 03 AM To: Rachel Cocalis <RCocalis@ rgrdlaw. com>; Tor Gronborg <TorG@ rgrdlaw. com> Cc: Ma, Charles <charles. ma@ kirkland. com>; Great, thanks. From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Wednesday, July 9, 2025 9:03 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Rachel, Let’s plan on Wednesday July 16 at 2 pm ET. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Tuesday, July 8, 2025 5:31 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Thanks, Kaitlin. We are available next Wednesday at 10 or 11 am PT/1 or 2 pm ET. If either of those times work for you, we can use the following dial-in: 267-930-4000 Code: 120021170. From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Thanks, Kaitlin. We are available next Wednesday at 10 or 11 am PT/1 or 2 pm ET. If either of those times work for you, we can use the following dial-in: 267-930-4000 Code: 120021170. Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 5 of 12 5 From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Tuesday, July 8, 2025 2:00 PM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thanks, Rachel. Totally understand. I am pretty flexible next Wednesday, July 16 (before 3 pm ET) or Thursday, July 17 (after 11 am ET). Let me know if either of those two days work for your schedule and if so a time period that works. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Tuesday, July 8, 2025 4:50 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, My apologies, but I’ve had a hearing scheduled in another case for that time. Do you all have any availability next week? Thank you, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Monday, July 7, 2025 Hi Kaitlin, My apologies, but I’ve had a hearing scheduled in another case for that time. Do you all have any availability next week? Thank you, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Monday, July 7, 2025 7:57 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thanks, Rachel. We are available for a meet and confer call on Thursday, July 10 at 8 am PT/11 am ET. Can you please circulate a calendar invite? Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 6 of 12 6 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Wednesday, July 2, 2025 6:31 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, Please see the attached Order entered yesterday regarding the Party’s scope dispute. Accordingly, we would like to continue our meet-and-confers. We are available next Wednesday from 12: 00-2: 30 pm PT or Thursday from 8: 00-9: 00 am Hi Kaitlin, Please see the attached Order entered yesterday regarding the Party’s scope dispute. Accordingly, we would like to continue our meet-and-confers. We are available next Wednesday from 12:00-2:30 pm PT or Thursday from 8:00-9:00 am PT. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Monday, June 9, 2025 3:00 PM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thank you for this update Rachel and agree to postpone the meet and confer until after the June 23 hearing. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Monday, June 9, 2025 5:38 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, A hearing on the Parties’ discovery dispute has been set for June 23, 2025. Accordingly, we think it makes most sense to postpone our meet and confer tomorrow until after the hearing. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Hi Kaitlin, A hearing on the Parties’ discovery dispute has been set for June 23, 2025. Accordingly, we think it makes most sense to postpone our meet and confer tomorrow until after the hearing. Thanks, Rachel Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 7 of 12 7 From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Thursday, June 5, 2025 10:58 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Thank you, Rachel. Confirming a M&C next Tuesday at 3 pm ET/noon PT. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Thursday, June 5, 2025 1:04 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Thank you, Kaitlin. We are available at 12: 00 pm PT/3: 00 pm ET on Tuesday. We can use the following dial-in: 267-930-4000 Code: 120021170. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Wednesday, June 4, Thank you, Kaitlin. We are available at 12:00 pm PT/3:00 pm ET on Tuesday. We can use the following dial-in: 267-930- 4000 Code: 120021170. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Wednesday, June 4, 2025 7:25 AM To: Rachel Cocalis <RCocalis@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Rachel, Yes, we are available for a meet and confer next week. Below are some dates/times that work for us: Tuesday (June 10) • Anytime before noon ET • Anytime after 3 pm ET Wednesday (June 11) • Anytime before noon ET • Anytime after 2 pm ET Thursday (June 12) Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 8 of 12 8 • Anytime after 3 pm ET Please let us know if any of those dates/windows work for your team. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com From: Rachel Cocalis <RCocalis@rgrdlaw.com> Sent: Tuesday, June 3, 2025 6:22 PM To: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com>; Tor Gronborg <TorG@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: RE: In re Carvana: K&E Responses and Objections to Subpoena Hi Kaitlin, Please let us know when you are available to meet and confer regarding the Responses and Objections. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin. sheehan@ kirkland. com> Sent: Friday, May 30, 2025 12: 01 PM To: Dan Drosman Hi Kaitlin, Please let us know when you are available to meet and confer regarding the Responses and ObjecƟons. Thanks, Rachel From: Sheehan, Kaitlin P. <kaitlin.sheehan@kirkland.com> Sent: Friday, May 30, 2025 12:01 PM To: Dan Drosman <DanD@rgrdlaw.com>; Tor Gronborg <TorG@rgrdlaw.com>; Rachel Cocalis <RCocalis@rgrdlaw.com>; Matthew Balotta <MBalotta@rgrdlaw.com>; Sarah Fallon <SFallon@rgrdlaw.com>; Erika Oliver <EOliver@rgrdlaw.com> Cc: Ma, Charles <charles.ma@kirkland.com>; Blackshear, Afi <afi.blackshear@kirkland.com> Subject: In re Carvana: K&E Responses and Objections to Subpoena EXTERNAL SENDER Counsel, Please see the aƩached. Please let us know if you have any quesƟons or want to discuss. Thanks, Kaitlin Kaitlin P. Sheehan ---------------------------------------- KIRKLAND & ELLIS LLP 601 Lexington Avenue, New York, NY 10022 T +1 212 909 3417 M +1 646 265 0660 F +1 212 446 4900 --------------------------------------- kaitlin.sheehan@kirkland.com Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 9 of 12 9 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 10 of 12 10 or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. NOTICE: This email message is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure by the attorney-client privilege, as attorney work product, or by other applicable privileges. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of the multi-national law firm Kirkland & Ellis LLP and/or its affiliated entities. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 11 of 12 11 notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. Case 2:22-cv-02126-MTL Document 364-2 Filed 04/27/26 Page 12 of 12
File and source
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- SHA-256
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- archive.org