they had already addressed in their instructions to the IT staff. The Court concludes that this factor tips against a finding of waiver in the present case. B. Scope of Discovery Versus Extent of Disclosure Courts generally decline to find waiver when “a relatively small number of privileged documents were disclosed in comparison to the total number of documents produced.” Asian Vegetable Research and Development Center v. Institute of International Education, 1995 WL 491491, at *7, 1995 U.S. Dist. LEXIS 11776, at *23 & n. 6 (S.D.N.Y. August 17, 1995) (finding twenty pages of inadvertently disclosed documents a “relatively small” number relative to the total of 75,000 pages produced). See also Lois Sportswear, U.S.A., Inc. v. Levi Strauss & Co., 104 F.R.D. 103, 105 (S.D.N.Y.1985) (<HOLDING>). This factor recognizes the reality that “it
holding loss of documents and death of witness did not impair defense where both events occurred when there was no presumption of prejudice holding an agency need not demonstrate that all responsive documents were found and that no other relevant documents could possibly exist holding that pursuant to the best evidence rule trial testimony relying on documents was inadmissible without submission of such documents or an explanation as to why the documents were unavailable holding that unauthorized disclosure of documents does not constitute a waiver of the applicable foia exemption holding that no waiver occurred when twentytwo protected documents were accidentally produced out of a total of 16000 pages reviewed