On 05/03/23, The Receiver filed a Reply [ECF No. 166] in support of a prior Motion to Compel [ECF No. 133]. In that filing, the Receiver acknowledges that it is common ground that a protocol for protecting attorney-client and work product privileges of Defendant Timothy Barton must be put in place. The Receiver had not met and conferred with the Defendant before making this proposal. The Defendant agrees that a privilege protocol should be entered and proposed herewith a revised protocol with certain crucial modifications. See Exhibit A (Defendant Barton’s proposed modified privilege protocol).