In re Carvana Co Securities Litigation

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
United Association National Pension
Fund, et al.,
Plaintiffs,
v.
Carvana Company, et al.,
Defendants.
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CASE NO. CV-22-02126-PHX-MTL
SPECIAL MASTER COHEN
RULING REGARDING TRANCHE
THREE OF CARVANA DOCUMENTS
This Honorable Court appointed the undersigned as Special Master to review in camera
documents withheld as privileged by Defendants. See docket no. 500 (“Appointment Order”). The
Special Master earlier issued rulings on a First Tranche and a Second Tranche of documents. See
docket nos. 552, 587.
Plaintiffs identified a Third Tranche of bellwether documents for in camera review,
consisting of 232 documents. Carvana responded by re-reviewing these documents, withdrawing
entirely its privilege claims for 132 of them, and producing the remaining documents in camera to
the Special Master, with supporting factual and legal explanations. (During its re-review, Carvana
may have also reduced the extent of its privilege claims for some of the remaining 100 documents
before submitting them—for example, by reducing the number of redactions—but the Special
Master does not have data on this detail.)
In the attached chart, the Special Master now provides rulings on Carvana’s privilege
claims for the remaining 100 documents. The Special Master applied the legal standards earlier
Case 2:22-cv-02126-MTL Document 650 Filed 08/25/26 Page 1 of 2

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set forth in the Tranche One and Tranche Two Rulings. See docket no. 552 at 2-9; docket no. 587
at 2-3.
RESPECTFULLY SUBMITTED,
/s/ David R. Cohen_
David R. Cohen
Special Master
Dated: August 26, 2026
Case 2:22-cv-02126-MTL Document 650 Filed 08/25/26 Page 2 of 2