From the Filing from pdf link in article: https://storage.courtlistener.com/recap/gov.uscourts.flsd.618763/gov.uscourts.flsd.618763.123.0.pdf

The problem is compounded by the fact that when Plaintiff’s counsel referred to either 11,000 pages or even 11,000 documents during the status conference (we are still awaiting the transcript), the Government chose not to interject with an accurate number. In conversations between Plaintiff’s counsel and the Government regarding a data vendor, the Government mentioned that the 11,000 documents contain closer to 200,000 pages.

Government counsel’s commentary regarding their compliance and our responsibilities misses the mark. A filter team, also known as a “taint” team, owes its very existence to the notion that using non-case agents and non-case attorneys is the best way to shield the case agents and attorneys from disqualification based on exposure to privileged documents. Judge Cannon has already noted that “the Privilege Review Team’s Report references at least two instances in which members of the Investigative Team were exposed to material that was then delivered to the Privilege Review Team and, following another review, designated as potentially privilege material [ECF No. 40 p. 6]. Those instances alone, even if entirely inadvertent, yield questions about the adequacy of the filter review process.” (ECF No. 64 p. 15). Judge Cannon further expressed that she was “not so sure” about the Privilege Review Team’s counsel’s characterization of those lapses as examples of the filter process working.”

On Monday, September 26, counsel for the Privilege Review Team provided Plaintiff’s counsel with another example of filter failure. The email in question was identified by the “FBI case team,” and returned to the Privilege Review Team, which is characterizing the communication as non-privileged. Plaintiff believes the email falls squarely into the category of attorney-client privileged. The Government also provided the Special Master and the Plaintiff with its third version of the inventory in this case, with 53 new documents, clippings, or photos appearing across 16 of the 33 item numbers. A prior entry for “2 empty folders with ‘CLASSIFIED’ Banners” has disappeared from Item #33. The unilaterally imposed filter team, which made no effort to contact Plaintiff’s counsel hroughout its review process, has admitted to three breaches so far. All this before review by the Special Master and the Plaintiff. By way of this filing, Plaintiff is asking the Special Master to order disclosure of the names of each attorney and Special Agent who was exposed to materials eventually provided to the Privilege Review Team