Sam is the CEO of giant inc. Giant is being sued by Webby, a competitor, for breach of contract. Sam says that he met with the CEO for Webby three times in 2017. Sam explains "he is lying when he said that we have never met we need his calendar check his secretary too". The meetings are a critical part of the Giants case. Giants lawyers: 1. We'll have to show the relevance of the calendars Beyond a reasonable doubt before They can get them 2. Cannot obtain the calendar due to privacy limitations 3. Can obtain the calendars using a request for production 4. Will not be able to obtain the calendar due to attorney client privilege