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. 9 ... ew c p101 esi%2

Lisa Borodkin <[e-mail]>

AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses
David Gingras <[e-mail]> Sun, May 30, 2010 at 7:02 PM Reply-To: [e-mail] To: Lisa Borodkin <[e-mail]> Cc: Maria Crimi Speth <[e-mail]>, Daniel Blackert <[e-mail]> Lisa,

You have requested no discovery from us relating to ESI or anything else, and you've indicated that you don't intend to so do. As such, I have no clue what ESI you want us to locate, preserve, or to provide you with a report about.

As we have told you from the beginning of the case, original author submissions are always preserved and are never changed. This is true of the reports about AEI, so your perception of an emergency is mistaken. As is true of virtually any website, peripheral parts of the site are always being reviewed and upgraded, so perhaps you're confused by some cosmetic and other change. However, as I understand it, your case is not based on any of these aspects of the site so I don't think this is a real concern.

If you would like to begin providing us with some additional information about your theory of the case, it's possible that we might begin to understand why ESI you feel is relevant, but at this point I see zero substantive purpose to your email below.

David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://w ww .ripoffreport.com/ [e-mail]

PO BOX 310, Tempe, AZ 85280 Tel.: [phone] Fax: [phone] From: Lisa Borodkin [mailto:[e-mail]] Sent: Saturday, May 29, 2010 2:44 PM To: <[e-mail]> Cc: Maria Crimi Speth; Daniel Blackert

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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...

Lisa Borodkin <[e-mail]>

AEI x. Xcentric: Request to Meet re Plaintiffs Discovery Responses
Lisa Borodkin <[e-mail]> Sun, May 30, 2010 at 7:25 PM To: [e-mail] Cc: Maria Crimi Speth <[e-mail]>, Daniel Blackert <[e-mail]> Metatags and HTML source for the reports at issue in the litigation. Please let me know if you want to confer on Tuesday at noon. Lisa
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7/29/2010 5:48 PM