Driscoll, 2020 WL 7711869 at *6 (brackets and quotation marks omitted) (quoting Youssef v. Bank of Am., No. CV 12-5364-GW (AGR), 2013 WL 12142563, at *4 (C.D. Cal. Sept. 24, 2013)); cf. Texas Brine Co., LLC & Occidental Chem. Corp., 879 F.3d 1224, 1228-31 (10th Cir. 2018) (dismissing defendant's appeal where defendant failed to produce privilege log after district court narrowed scope of challenged subpoena and gave defendant “a second chance” to produce log). “Otherwise, any objection to the scope of a discovery demand would be rendered moot because interposing that objection would trigger the very burdensome obligation to prepare a privilege log that the objection would be intended to avoid.” In re Application for an Order Pursuant to 28 U.S.C. § 1782 to Conduct Discovery for Use in a Foreign Proceeding, 286 F.Supp.3d 1, 7 (D.D.C. 2017); see also, e.g., Aetna Inc. v. Mednax, Inc., No. 18-CV-02217-WB, 2019 WL 6250850, at *7 (E.D. Pa. Nov. 22, 2019) (declining to require privilege log where burden of “laborious privilege review” would “far exceed any likely benefit, in terms of relevant documents that for some reason escape privilege or work product protection”); Dell Inc. v. DeCosta, 233 F.Supp.3d 1, 3-4 (D.D.C. 2017) (narrowing subpoena where “most” of the responsive documents defendant “could reasonably be expected to ‘possess'” would be privileged or protected and preparation of privilege log “would impose an undue and disproportionate burden”). Here, Movants objected to and have moved to quash Plaintiff's Subpoenas based not only on the attorney-client privilege and attorney work-product doctrine, but also on undue burden, overbreadth, and lack of relevance and proportionality.
Likewise, when addressing any issue based heavily on witness testimony, a witness' knowledge, credibility, and potential biases are "relevant." Fed. R. Evid. 401; see United States v. Abel, 469 U.S. 45, 52 (1984) (witness bias is almost always relevant and provable by extrinsic evidence, in contrast to less favored forms of impeachment); Aetna Inc. v. Mednax, Inc., 2019 WL 6250850, at *6 (E.D. Pa. Nov. 22, 2019) (discovery of consulting agreements and nondisclosures agreements for former employees bear on witness credibility and are discoverable). Here, the declarants were Atty.