When a party withholds documents from production on privilege grounds, it generally must produce a log describing each one in enough detail for the other side and the court to assess the claim — typically date, author, recipients, type, and the basis asserted, without revealing the privileged content itself.
Logs go wrong in predictable ways. Entries so vague they cannot be assessed (“email re legal matters”) invite a challenge and sometimes a finding of waiver. Documents copied to non-privileged third parties should not be on the log at all. Communications with in-house counsel acting in a business rather than legal capacity are frequently over-designated, and a log full of them undermines the credibility of the genuine claims.
Practical guidance: log at the document level with real descriptions, exclude anything whose distribution destroyed the privilege, and be conservative. A short defensible log is worth far more than a long one that draws a motion — and courts have limited patience for blanket assertions.