Excluded Records. The term “Excluded Records” shall be defined as: (1) any notes, memoranda, e-mails or other correspondence or communications that relate to any claims or potential claims of the Debtors against any of the KPN Entities that were created by or exchanged between any of the professionals retained in the Cases and/or any employee of the Debtors; or (2) any of the Debtors’ Records that are both protected by the attorney-client privilege or any other applicable privilege or doctrine, including the attorney work-product doctrine and that are related to the Debtors’ disputes or causes of action on the list attached hereto as Exhibit A..
Appears in 2 contracts
Sources: Settlement Agreement, Settlement Agreement