Still - who said "we got what we wanted" ... gotcha! Congrats on the win.
What do you think the likelihood is that you will get a PMK w/i the Legal Department who will respond in a full manner to questions posed? To often we hear about the selective memory of those who testify on behalf of the WTBTS. The "don't recall" and "don't know" approach to deposition questions is not uncommon for them.
I apologize because I have not read the pleadings, but are the telememos forms filled out by the BOE when someone has been reported as a per in the congo? And if so, I am confused as to how this can be deemed privileged when it sounds like it is a form that is used more as a custom and practice, so how would the party who is filling it out know it came from the "legal department" and thus be deemed communication with counsel?