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. 8 ... ew c p101 esi%2

Lisa Borodkin <[e-mail]>

AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses
Lisa Borodkin <[e-mail]> Sat, May 29, 2010 at 2:44 PM To: "<[e-mail]>" <[e-mail]> Cc: Maria Crimi Speth <[e-mail]>, Daniel Blackert <[e-mail]> Thanks. How about noon on Tuesday? Also, please give us your statement on ESI. The website is on and off. We need to know what backup tapes, disks, recovery, and otherwise overwriting precautions you are taking to preserve data. I'd prefer not to do this, but we may need to apply ex parte for a TRO if we cannot confirm a statement from you regarding preservation of ESI. Lisa On May 29, 2010, at 10:38 AM, "David Gingras" <[e-mail]> wrote: Lisa,

I don't think the court will appreciate any party making clever (and disingenuous) technical arguments to avoid having to provide crucial discovery especially given your previous representations to the court about being ready to proceed immediately, but we can discuss this further when we meet and confer on Tuesday.

Having said this, and without agreeing that I am under any obligation to do so, I'm re-serving our discovery requests which are attached (note ­ some changes have been made). Depending on various factors, I may or may not still move forward with a motion to compel, but while that issue is being decided, you can go ahead and provide full and complete answers to these new requests by June 29 .
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David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ [e-mail] <image001.jpg>
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Gmail - AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses

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<AEI v. Xcentric - Defendants' FIRST Re-Served Discovery.pdf>

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