Asia Economic Institute et al v. Xcentric Ventures LLC et al

Filing 101

EX PARTE APPLICATION for Order for Temporary Restraining Order for Preservation of Electronically Stored Information (ESI), EX PARTE APPLICATION for Protective Order for Preventing Interference with Witnesses filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 1 to Declaration of Lisa J. Borodkin (April 22, 2010 email), # 2 Exhibit 2 to Declaration of Lisa J. Borodkin (April 27, 2010 email), # 3 Exhibit 3 to Declaration of Lisa J. Borodkin (April 27, 2010 email), # 4 Exhibit 4 to Declaration of Lisa J. Borodkin (Rule 26(f) Report), # 5 Exhibit 5 to Declaration of Lisa J. Borodkin (March 2009 Google results), # 6 Exhibit 6 to Declaration of Lisa J. Borodkin (August 2010 Google results), # 7 Exhibit 7 to Declaration of Lisa J. Borodkin (May 28, 2010 email), # 8 Exhibit 8 to Declaration of Lisa J. Borodkin (May 29, 2010 email), # 9 Exhibit 9 to Declaration of Lisa J. Borodkin (May 30, 2010 email), # 10 Exhibit 10 to Declaration of Lisa J. Borodkin (May 30, 2010 email), # 11 Exhibit 11 to Declaration of Lisa J. Borodkin (Plaintiffs' RFPs), # 12 Exhibit 12 to Declaration of Lisa J. Borodki (July 14, 2010 email), # 13 Exhibit 13 to Declaration of Lisa J. Borodkin (Defendants' Responses to RFPs), # 14 Exhibit 14 to Declaration of Lisa J. Borodkin (July 30, 2010 emails), # 15 Exhibit 15 to Declaration of Lisa J. Borodkin (Declaration of Kenton Hutcherson), # 16 Exhibit 16 to Declaration of Lisa J. Borodkin (Demand letter fron Defendants))(Borodkin, Lisa)

Gmasla Economic Institute et alto Meet re Plaintiffs Discovery Responses A i i - AEI x. Xcentric: Request v. Xcentric Ventures LLC et al

https://mail.google.com/mail/?ui=2&ik=0d9198f21b&viDo=. t&q=Att. 7 ... ew c p101 esi%2

Lisa Borodkin <[e-mail]>

AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses
Lisa Borodkin <[e-mail]> Fri, May 28, 2010 at 11:34 AM To: "<[e-mail]>" <[e-mail]>, Maria Crimi Speth <[e-mail]> Cc: Daniel Blackert <[e-mail]>, [e-mail], [e-mail] Hi David, We can meet and confer Tuesday. Please suggest a time. We have been getting some documents ready to send you but if you would like to come inspect and make copies yourself you are welcome to do so, subject to our objection that your requests were premature. The documents are at AEI's office. I am not sure as a matter of law that you will get an order on those requests if you bring a motion to compel. I actually think your requests may be void because you served them before the Rule 26(f) conference. But I'd rather spend the time getting you documents. We are also very concerned that thr RipoffReport.com website seems to be changing. We are concerned electronic evidence may be destroyed. I would like a statement as to what you have done to preserve ESI in this case, and to confer on that. Lisa

On May 27, 2010, at 5:05 PM, "David Gingras" <[e-mail]> wrote: Dan & Lisa,

Please review the attached letter and respond as soon as possible.

David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ [e-mail] <image001.jpg> PO BOX 310, Tempe, AZ 85280 Tel.: [phone] Fax: [phone]

1 of 2

Docke2s.Justia.com 7/ t 9/2010 5:45 PM

Gmail - AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses

https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view =pt&q=esi%2...

<Ltr - Dan & Lisa - 5-27-2010.pdf>

2 of 2

7/29/2010 5:45 PM