Reply to Response — United States ex rel. James R. Berkley v. Ocean State, LLC (Dkt. 52, D.R.I.)

Summary

The relator's reply in support of the motion to compel discovery of attorney-client communications about the PPP loans, filed June 7, 2024 as Document 52 in United States ex rel. James R. Berkley v. Ocean State, LLC, C.A. No. 1:20-cv-00538-JJM-PAS, in the U.S. District Court for the District of Rhode Island. The relator argues that the defendants' subjective good faith belief defense, and their reliance on redacted emails, business case memos and board consents prepared with counsel's advice, waive the privilege. It argues that the Janssen Biotech decision relied on in the opposition is distinguishable and supports the relator. It states the relator's contention that Ocean State and New Harbor Capital conspired to falsely claim the SBIC affiliation waiver. The reply is signed /s/ by Eric E. Renner.

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