[brief] R. 4:10-2(e)(1) provides as follows:  (e)  Claims of Privilege or Protection of Trial Preparation Materials.  --- \(^{13}\)  Respondents, when citing to *O Builders*, failed to include this very important paragraph in their Brief in an apparent attempt to mislead the Court.  \(^{14}\)  Despite Respondents’ claim that they should have access to [...]’s Certification, in contradiction to *O Builders* they cite to no authority for such claim.  RB16-17.  (1)  Information Withheld.  When a party withholds information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents, communications, or other things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.  Here, Petitioners made their submission of [...]’s Certification for *in camera* review in accordance with Rule 4:10-2(e)(1).  First, Petitioners made their claim expressly and described the name of the document not disclosed in a manner to allow Respondents to assess the applicability of the protection of as follows:  (1)  Petitioners submitted correspondence to the Trial Court, on which [...] was copied, stating “. . . please note that given the sensitive nature of the subject motion, the Certification of [...] is being provided to the Court only for *in camera* review. ”  Pa126.  Second, Petitioners’ letter brief submitted to the Trial Court, on which [...] was also copied, stated regarding the substantially harmful information imparted to [...] and contained in [...]’s Certification, “The specific details of these communications are contained within the Certification of [...] which is being submitted herewith for *ex parte in camera* review by the Court. ”  Such letter brief also generally summarized the contents of [...]’s Certification and warned of its prejudicial nature.  PPa81.  In addition, such Certification provided Respondents with more than sufficient information to respond appropriately.  In any event, [...] was a participant in the conversations with [...] and knows full well what was discussed.  In accordance with Rule 4:10-2(e)(1), Petitioners expressly advised Respondents in their Trial Court correspondence and pleadings the nature of the document submitted \textit{in camera}, in a manner not revealing the protected information itself, which allowed [...] to assess the applicability of the privilege or protection.  That document is [...]’s Certification.\footnote{As conceded by Respondents, emails annexed as exhibits to [...]’s Certification were already in the possession of [...].  RB5-6.}  [...]’s Certification provided specific information regarding her conversations with [...].  The information contained in [...]’s Certification clearly evidenced that the information disclosed would be significantly harmful to Petitioners in Respondents’ hands.  In generally summarizing the contents of [...]’s Certification, Petitioners not only complied with \textit{O Builders} and Rule 4:10-2(e)(1), they provided Respondents more than sufficient information to respond appropriately to Petitioners’ Motion to Disqualify. \textsuperscript{16}  PPa81.  Based on \textit{O Builders} and Rule 4:10-2(e)(1), the Petitioners satisfied their obligation on how the confidential information was to be submitted to the Trial Court.  \textbf{POINT IV}