Bryan Pringle v. William Adams Jr et al

Filing 206

DECLARATION of Tal E. Dickstein in response to MOTION to Withdraw Transcripts and Re-File Portions of Previously Filed Transcripts Under Seal 202 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Miller, Donald)

&IELD
LER

Founded in 1852
by Sidney Davy Miller

Miller, Canfield, Paddock and Stone, P.L.C.
225 W. Washington, Suite 2600
Chicago, Illinois 60606
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www.millercanfield.corn

KATHARINE N. DUNN
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June 20, 2011
Via Email
Tal Dickstein
LOEB & LOEB

345 Park Avenue
New York, NY 10154
RE:

Pringle v. William Adams, et al.

Dear Tal:
We are in receipt of the documents marked as Riesterer0000001-0000037
and Shapiro0000001-0007497. Please advise whether those documents are a
complete document production by Defendants Shapiro, Bernstein & Co., Inc. and
Mr. Riesterer. Assuming that those Defendants' document production is complete,
we write to request a meet and confer with respect to the Defendants' document
production on what we have evaluated as a variety of issues. We further write to
request a meet and confer with respect to the lack of production of any documents
by Mr. Guetta.
First, we note that many of the documents have been improperly redacted
despite both "confidential" and "highly confidential" designations. Second, we
believe that many of the documents have been improperly designated in both the
"confidential" and "highly confidential" categories and we would like to challenge
many of the designations. And, lastly, we note that the document production is
woefully deficient in substance, with entire categories of documents (such as
emails) withheld based on what we believe to be improper objections by
Defendants.
As you know, Mr. Riesterer's deposition is scheduled to proceed on
Thursday. Accordingly, given such a short timeframe, we request a meet and
confer tomorrow, June 21, 2011, with respect to the Defendants' document
production. Please advise as to your availability.
Very truly yours,
MILLER ANFIELD, P

11"
tha ne N. Dunn
KND/bs
cc:
Counsel of Record
MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.