EXHIBIT 4

   

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 1 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 1 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

1

Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Summary Report by 

Stroz Friedberg, LLC 

(“Investigation Report”) 

Regarding Investigation 

Relating to Acquisition 

of Ottomotto by Uber 

(the “Due Diligence 

Investigation”).

AC / 

WP/JI2

Uber InHouse 

Counsel

Investigation report prepared at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

Uber affirms that to its knowledge no 

unauthorized persons have received the 

Investigation Report. Specifically, to Uber’s 

knowledge the only recipients of this 

document are the original recipients—those 

listed in the Recipient(s) column—and Uber’s 

in-house counsel, Ottomotto’s in-house 

counsel, and Outside Counsel of Record in 

this litigation. Pursuant to a common interest 

agreement dated April 11, 2016 and entered 

into by counsel for Uber, counsel for 

Ottomotto, counsel for A. Levandowski, and 

counsel for Lior Ron, the recipients of the 

Investigation Report (including its 

attachments) were contractually obligated to 

not disclose it to any other persons except for 

in-house counsel for Uber, in-house counsel 

for Ottomotto, outside counsel for those 

entities, outside counsel for A. Levandowski, 

and outside counsel for Lior Ron.

2

Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

March 

21, 2016

Attachment to 

Investigation Report. 

Memorandum regarding 

investigation protocol for 

the Due Diligence 

Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Memorandum prepared as 

part of investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

 

1

Individuals from each entity identified as an author or recipient are listed on page 17, as are recipients from Uber and Otto.

2 The invocation of the privileges on this log are pursuant to the “Joint Defense, Common Interest, and Confidentiality Agreement” filed with the Court with Anthony Levandowski’s motion, filed on April 4, 2017.

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 2 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 2 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

3

John Gardner, 

Donahue 

Fitzgerald LLP

Stroz Friedberg

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Levine & Baker LLP (outside 

counsel for Lior Ron)

March 

21, 2016

Correspondence between 

Stroz Friedberg, LLC and 

attorney for A. 

Levandowski regarding 

investigation protocol for 

the Due Diligence 

Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Correspondence relating 

to investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

4

Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

March 

4, 2016

Correspondence 

regarding engagement of 

Stroz Friedberg, LLC for 

purposes of conducting 

the Due Diligence 

Investigation and 

memorandum regarding 

investigation protocol for 

the Due Diligence 

Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Correspondence relating 

to investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

5

Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

April 2, 

2016

Memorandum regarding

analysis of information 

ascertained from A. 

Levandowski during the 

Due Diligence 

Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Memorandum prepared as 

part of investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 3 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 3 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

6

Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

April 

12, 2016

Memorandum regarding 

analysis of information 

ascertained from L. Ron 

during Due Diligence 

Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Memorandum prepared as 

part of investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

7* Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Report generated during 

Due Diligence 

Investigation 

summarizing analysis of 

electronic media 

collected from A. 

Levandowski.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Report of forensic analysis 

prepared as part of investigation 

conducted at direction of counsel 

for Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with

potential acquisition of Ottomotto 

in anticipation of potential 

litigation.

[same as Index No. 1]

8* Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Report generated during 

Due Diligence 

Investigation 

summarizing analysis of 

electronic media 

collected from A. 

Levandowski.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Report of forensic 

analysis prepared as part of 

investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto in 

anticipation of potential litigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 4 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 4 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

9* Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)O’Melveny & 

Myers LLP (outside counsel for 

Otto)Donahue Fitzgerald LLP 

(outside counsel for 

Levandowski)Levine & Baker 

LLP (outside counsel for Lior 

Ron)

August 

5, 2016

Report generated during 

Due Diligence 

Investigation 

summarizing analysis of 

electronic media 

collected from A. 

Levandowski.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Report of forensic 

analysis prepared as part of 

investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto in 

anticipation of potential litigation.

[same as Index No. 1]

10* Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Report generated during 

Due Diligence 

Investigation 

summarizing analysis of 

electronic media 

collected from A. 

Levandowski.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Report of forensic 

analysis prepared as part of 

investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto in 

anticipation of potential litigation.

[same as Index No. 1]

11 Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

July 28, 

2016

Memorandum regarding 

investigation 

methodology for Due 

Diligence Investigation.

AC / 

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Memorandum prepared as 

part of investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 5 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 5 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

12 Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

2, 2016

Memorandum regarding 

analysis of information 

ascertained from 

potential witnesses 

during Due Diligence 

Investigation.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Memorandum containing 

the mental impressions, 

conclusions, and opinions of the 

author prepared as part of 

investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto in 

anticipation of potential litigation.

[same as Index No. 1]

13** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 6 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 6 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

14** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

15** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Communications 

collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

16** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Stroz Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 7 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 7 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

17* Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)O’Melveny & 

Myers LLP (outside counsel for 

Otto)Donahue Fitzgerald LLP 

(outside counsel for 

Levandowski)Levine & Baker 

LLP (outside counsel for Lior 

Ron)

August 

5, 2016

Report generated during 

Due Diligence 

Investigation 

summarizing analysis of 

electronic media 

collected from A. 

Levandowski.

WP/JI

Uber InHouse 

Counsel

Attachment to Investigation 

Report. Report of forensic 

analysis prepared as part of 

investigation conducted at 

direction of counsel for Uber for 

purposes of providing legal advice 

to Uber, in anticipation of 

litigation, re: due diligence in 

connection with potential 

acquisition of Ottomotto in 

anticipation of potential litigation.

[same as Index No. 1]

18** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Communications 

collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

19** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 8 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 8 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

20** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

21** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

22** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 9 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 9 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

23** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

24** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg during Due 

Diligence Investigation 

and appended to 

Investigation Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 10 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 10 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

25** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

26** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)O’Melveny & 

Myers LLP (outside counsel for 

Otto)Donahue Fitzgerald LLP 

(outside counsel for 

Levandowski)Levine & Baker 

LLP (outside counsel for Lior 

Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 11 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 11 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

27** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 12 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 12 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

28** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

29** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

30** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 13 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 13 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

31** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

32** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

33** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 14 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 14 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

34** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)O’Melveny & 

Myers LLP (outside counsel for 

Otto)Donahue Fitzgerald LLP 

(outside counsel for 

Levandowski)Levine & Baker 

LLP (outside counsel for Lior 

Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

35** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

36** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 15 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 15 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

37** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

38** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

39** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 16 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 16 of 17

INDEX 

NO.*,**

AUTHOR(S) OF 

DOCUMENT RECIPIENT(S) OF DOCUMENT1

DATE 

OF DOCUMENTSUBJECT MATTER

NATURE 

OF 

PRIVILEGE

LOCATION 

WHERE 

DOCUMENT 

WAS FOUND

BASIS FOR UBER’S ASSERTION OF 

PRIVILEGE

AFFIRMATION OF STEPS TAKEN TO ENSURE 

CONFIDENTIALITY AND NON-RECEIPT BY 

UNAUTHORIZED PERSONS

40** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

41** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

File collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of document for 

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

42** Stroz Friedberg, 

LLC

Morrison & Foerster LLP (outside 

counsel for Uber)

O’Melveny & Myers LLP (outside 

counsel for Otto)

Donahue Fitzgerald LLP (outside 

counsel for Levandowski)

Levine & Baker LLP (outside 

counsel for Lior Ron)

August 

5, 2016

Files collected from A. 

Levandowski and 

obtained by Stroz 

Friedberg, LLC during 

Due Diligence 

Investigation and 

appended to Investigation 

Report. 

WP/JI

Uber InHouse 

Counsel

Attachment to investigation report 

prepared at direction of counsel for 

Uber for purposes of providing 

legal advice to Uber, in 

anticipation of litigation, re: due 

diligence in connection with 

potential acquisition of Ottomotto. 

Selection of documents for

inclusion in report reflects thought 

process of investigators retained to 

perform investigation.

[same as Index No. 1]

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 17 of 18
Waymo LLC v. Uber Technologies, Inc., et al., No. 3:17-cv-00939-WHA (N.D. Cal.)

Defendants’ Privilege Log Associated with March 31, 2017 Production of Documents 

*With respect to memoranda/reports marked with a single asterisk, the reports themselves (which, on their own, constitute work product) are undated. The date of the report/memorandum listed in this log is the date of the 

Investigation Report.

**With respect to documents marked with two asterisks, the date of the document in this log is listed as the date of the Investigation Report, as it is the selection for and inclusion in that report that forms the basis for the 

assertion of work product privilege. The author of these documents is listed as Stroz Friedberg, LLC because it is the entity who selected the documents for inclusion in the Investigation Report. The author of the underlying 

communication(s)/document(s) is not listed in this privilege log because doing so would reveal the work product over which privilege is being asserted.

Page 17 of 17

Stroz Friedberg LLC Morrison & Foerster LLP

Judith Branham Eric Tate

Scott Brown Anna Ferrari

Hanley Chew Elizabeth Balassone

Eric Friedberg Shouvik Biswas

Mary Fulginiti Elizabeth Crandall-Whittom

Melanie Maugeri Sarah Davis

Mitchell Dobi Derek Foran

Cristina Antalik Teresa MacLean

Jessica Madore Colette Reiner Mayer

Frances Sagapolu

Diek Van Nort

Ethel Villegas

Uber Technologies, Inc. Ben Williams

Andrew Glickman, Esq.

Todd Hamblet, Esq.

Christian Lymn, Esq. O’Melveny & Myers LLP

Angela Padilla, Esq. Eric Amdursky

Justin Suhr, Esq. Paul Sieben

Robert Wu, Esq.

Salle Yoo, Esq.

Ottomotto LLC Donahue Fitzgerald LLP

Adam Bentley, Esq. John F. Gardner

Anthony Levandowski Branden Clary

Lior Ron

Levine & Baker LLP

Alisa J. Baker

Case 3:17-cv-00939-WHA Document 370-4 Filed 05/08/17 Page 18 of 18