NovaStream Logistics, LLC Privilege Log
Case: Washington v. NovaStream Logistics, LLC
Docket No.: ESX-L-001847-26
Date: March 20, 2026
In response to Plaintiff's First Request for Production of Documents, Defendant NovaStream Logistics, LLC withholds the following documents on the basis of attorney-client privilege and/or work product protection.
Documents Withheld
| Entry | Date | Author | Recipient(s) | Document Type | Subject Matter | Privilege Claimed |
|---|---|---|---|---|---|---|
| 1 | 02/03/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding engagement scope and classification risk assessment | Attorney-Client | |
| 2 | 02/04/2026 | Rachel Dominguez-Park, Esq. | Associate Team | Memorandum | Attorney work product analyzing ABC test and research assignment | Attorney-Client; Work Product |
| 3 | 02/10/2026 | Associate (name redacted) | Rachel Dominguez-Park, Esq. | Memorandum | Draft research memo on NJ classification law | Work Product |
| 4 | 02/14/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding IC agreement provisions and classification risk | Attorney-Client | |
| 5 | 02/20/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice responding to client questions about GWANJ redline | Attorney-Client | |
| 6 | 02/22/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma, Marcus Chen | Legal advice regarding response to GWANJ proposals | Attorney-Client | |
| 7 | 09/16/2025 | Priya Sharma | Marcus Chen | Slack DM | Communication relaying legal advice from counsel regarding workers' comp response | Attorney-Client |
| 8 | 09/28/2025 | Priya Sharma | Marcus Chen | Slack DM | Communication referencing intent to consult with counsel | Attorney-Client |
| 9 | 10/03/2025 | Priya Sharma | Marcus Chen | Slack DM | Communication regarding litigation hold and document preservation | Attorney-Client; Work Product |
| 10 | 10/05/2025 | Rachel Dominguez-Park, Esq. | NovaStream Leadership | Memorandum | Litigation hold memo prepared in anticipation of litigation | Attorney-Client; Work Product |
| 11 | 10/08/2025 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding response to McAllister inquiry | Attorney-Client | |
| 12 | 02/26/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding demand letter response strategy | Attorney-Client; Work Product | |
| 13 | 02/27/2026 | Rachel Dominguez-Park, Esq. | NovaStream Leadership | Memorandum | Analysis of demand letter claims and litigation risk assessment | Attorney-Client; Work Product |
| 14 | 03/01/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding complaint response strategy | Attorney-Client; Work Product | |
| 15 | 03/05/2026 | Associate (name redacted) | Rachel Dominguez-Park, Esq. | Memorandum | Draft answer and affirmative defenses | Work Product |
| 16 | 03/10/2026 | Rachel Dominguez-Park, Esq. | Priya Sharma | Legal advice regarding discovery strategy | Attorney-Client; Work Product | |
| 17 | 03/12/2026 | Rachel Dominguez-Park, Esq. | Marcus Chen | Legal advice regarding document collection for discovery | Attorney-Client | |
| 18 | 03/20/2026 | Rachel Dominguez-Park, Esq. | Diane Okonkwo | Legal advice regarding payroll record production | Attorney-Client |
Notes on Specific Entries
Entry 7 (September 16, 2025 Slack DM)
This communication from Priya Sharma to Marcus Chen relays legal advice received from outside counsel Rachel Dominguez-Park regarding NovaStream's response to Plaintiff's workers' compensation inquiry. The communication states that the CEO "talked to Rachel" and conveys counsel's advice about how to respond. While the communication is between two NovaStream employees, it reflects and relays attorney-client privileged advice.
See State v. Mauti, 208 N.J. 519, 537 (2012) (privilege extends to communications within corporate client conveying attorney advice).
Entry 8 (September 28, 2025 Slack DM)
This communication references the CEO's intent to "check with Rachel" before responding to a situation. While the communication itself does not contain legal advice, it reflects the confidential consultation process and is protected as part of the attorney-client relationship.
Entry 9 (October 3, 2025 Slack DM)
This communication discusses the litigation hold and document preservation instructions received from counsel. It is protected as both attorney-client communication (conveying legal advice about preservation obligations) and work product (prepared in anticipation of litigation).
Certification
I certify that the documents listed above have been withheld in good faith based on applicable privileges, and that the descriptions provided are sufficient to enable Plaintiff to evaluate the privilege claims without revealing privileged content.
Rachel Dominguez-Park, Esq.
Attorney for Defendant NovaStream Logistics, LLC
Dated: March 20, 2026
Documents Produced with Redactions
In addition to the documents withheld in full, the following documents have been produced with limited redactions to protect privileged content:
| Document | Redaction Description | Privilege Basis |
|---|---|---|
| Slack Channel #driver-ops (07/12/2025 - 10/03/2025) | Redacted portions of certain messages where content reflects legal advice | Attorney-Client |
| Email from Priya Sharma to Marcus Chen (02/20/2026) | Redacted one paragraph discussing legal strategy | Attorney-Client; Work Product |
| Internal Memo re: Driver Classification (01/2025) | Redacted section containing legal analysis | Attorney-Client; Work Product |
Unredacted versions of these documents are being preserved and can be submitted for in camera review if Plaintiff challenges the redactions.