City of Winter Haven v. Cleveland Indians Baseball Company Limited Partnership

Filing 294

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA Orlando Division In Re: Seroquel Products Liability Litigation MDL Docket No. 1769 Case No. 6:06-md-01769-ACC-DAB

DOCUMENT RELATES TO ALL CASES

EXHIBIT LIST
_____Government __X_ Plaintiff _____Defendant Exhibit No. 1 Date Identified Date Admitted Witness Objection _____Court Description of Exhibit Declaration of John Martin in Support of Plaintiffs' Motion for Order Imposing Discovery Sanctions Exhibit 1 to Martin Declaration : Martin CV Exhibit 2 to Martin Declaration: Article "The New Phone Concept Supports the Business Process" by Marc Schneider Exhibit 3 to Martin Declaration: e-mail of 9/4/03 re question concerning medwatch Exhibit 4 to Martin Declaration: Seroquel Internal PR Milestones 2003-2004

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Exhibit 5 to Martin Declaration: e-mail of 10/209/03 re preparation for Seroquel labeling negotiations Exhibit 6 to Martin Declaration: Certification of Complete Custodial Production Exhibit 7 to Martin Declaration: e-mail re MEDHIST & CONMED Exhibit 8 to Martin Declaration: Plaintiff AZ Search Terms List 7/19/07 Exhibit 9 to Martin Declaration: article from ibis Consulting, Inc. Exhibit 10 to Martin Declaration: document tracking printout re AZSER0929181 Exhibit 11 to Martin Declaration: re AZSER08094539 Exhibit 12 to Martin Declaration: Metadata from the email AZSER08028911 Partial transcript from 9/7/06 hearing Partial transcript from 11/6/06 hearing Partial transcript from 11/20/06 hearing Partial transcript from 12/11/06 hearing

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Partial transcript from 12/12/06 hearing Partial transcript from 3/2/07 hearing Partial transcript from 4/12/07 hearing Partial transcript from 5/22/07 hearing Partial transcript from 6/13/07 hearing Court Order of 1/26/07 Plaintiffs' Joint Statement of Resolved Issues and Notice That a Hearing Is Not Required Plaintiffs' Motion For an Order 1. compelling Defendants to Provide Complete Certified Production of the First Eight Custodial Files and All Other Custodial Files Produced to Date; 2. Suspending the Custodial Production Method Upon Completion of the Production of the Outstanding Custodial Files Produced to Date; and 3. Immediately Permitting Plaintiffs to Proceed by a Notice to Produce Method of Discovery Defendant AstraZeneca's Opposition to Plaintiffs' Motion to Compel Discovery 9/11/06 Order and Notice of Hearing

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Declaration of Jonathan Jaffe in Support of Plaintiffs' Motion For Order Imposing Discovery Sanctions Exhibit 1 to Jaffe Declaration: 11/17/06 email re Production Requirements Exhibit 2 to Jaffe Declaration: first 8 custodians Exhibit 3 to Jaffe Declaration: 1/11/07 email re Seroquel MDL document production Exhibit 4 to Jaffe Declaration: 1/29/07 email re Seroquel MDL sample MDL production Exhibit 5 to Jaffe Declaration: 2/2/07 email re document production Exhibit 6 to Jaffe Declaration: 3/14/07 email re additional issues with custodial production format Exhibit 7 to Jaffe Declaration: 6/5/07 email re meet and confer Exhibit 8 to Jaffe Declaration: 6/5/07 email re IT issues and their status Exhibit 9 to Jaffe Declaration: 6/5/07 email re today's meet and confer Exhibit 10 to Jaffe Declaration: 6/25/07 email re Update on Technical Issues

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Exhibit 11 to Jaffe Declaration: 6/27/07 email re: continuing IT production failures Exhibit 12 to Jaffe Declaration: 6/29/07 re technical fix issues Exhibit 13 to Jaffe Declaration: 7/11/07 email from Pennock Exhibit 14 to Jaffe Declaration: 7/13/07 email from Yeager Exhibit 15 to Jaffe Declaration: 7/20/07 email from Yeager Exhibit 16 to Jaffe Declaration: Confidential Doc. And attached metadata Exhibit 17 to Jaffe Declaration: Query used for extraction Exhibit 18 to Jaffe Declaration: e-mail 1/19/07 from Eben Flaster Exhibit 19 to Jaffe Declaration: 6/11/06 email from Freebery Exhibit 20 to Jaffe Declaration: 6/13/07 from Dupre Exhibit 21 to Jaffe Declaration: 6/14/07 from Dupre Exhibit 22 to Jaffe Declaration: 6/19/07 from Dupre Exhibit 23 to Jaffe Declaration: 6/20/07 from Dupre Exhibit 24 to Jaffe Declaration: 6/27/07

from Pennock 16.25 Exhibit 25 to Jaffe Declaration: 7.2.07 from Dupre Certification of Michael E. Pederson Exhibit 1 to Pederson Certification: series of E-mails received by me on February 21, 2007, in which I was cc'd, that addressed defendants document production and concerns plaintiffs were having with the pace and technical content of the productions. Exhibit 2 to Pederson Certification: E-mail from Shane Prince, which included an attached draft of defendants proposed CMO 4 with Appendix A. attached thereto. Appendix A is now Exhibit 2 attached hereto. Exhibit 3 to Pederson Certification: E-mail I received on April 10, 2007, which advised plaintiffs that defendants were still working on problems plaintiffs were having with reviewing the Excel spreadsheets and the TIFF images, which did not fully recreate the native formatting of the

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documents. 17.4 Exhibit 4 to Pederson Certification: letter dated April 13, 2007, which I sent via regular mail to James J. Freebery, regarding ongoing document production problems plaintiffs were having. Exhibit 5 to Pederson Certification: E-mail dated April 19, 2007, which confirms that James J. Freebery received my letter of April 13, 2007, which had subsequently been E-mailed to him on April 18, 2006, by my legal assistant Yommy Chiu. Exhibit 6 to Pederson Certification: E-mail dated April 19, 2007, which I received from Roddy K. Miller in response to an E-mail I had earlier sent him concerning problems plaintiffs were having with the images plaintiffs were seeing in the productions. Exhibit 7 to Pederson Certification: letter dated April 30, 2007, with attachments, which I received from James J. Freebery, that purported to address concerns raised in my prior letter dated April 13, 2007,

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which was E-mailed to defendants on April 18, 2007. Exhibit 8 to Pederson Certification: E-mail and attached letter dated May 21, 2207, which I sent to James J. Freebery, which further outlined and clarified continuing technical issues plaintiffs were having with defendants productions Exhibit 9 to Pederson Certification: E-mail I received from James J. Freebery on May 21, 2007, which confirmed he had received my Exhibit 8 letter. Exhibit 10 to Pederson Certification: last Email in a string of Emails, between James J. Freebery and I, which addressed the technical issues plaintiffs intended to discuss during the parties Meet and Confer scheduled for May 30, 2007 Exhibit 11 to Pederson Certification: Andrew Dupre E-mail with attached letter from James J. Freebery, which I received on May 31, 2007, that listed defendants understanding of the status of the technical issues raised by plaintiffs during the parties Meet

and Confer of May 30, 2007. 17.12 Exhibit 12 to Pederson Certification: E-mail letter prepared by me and sent by my legal assistant Yommy Chiu to James J. Freebery on May 31, 2007, which is a summary of plaintiffs understanding of the status of the technical issues discussed during the parties meet and Confer on May 30, 2007. Excerpt from 5/14/07 deposition of Ann V. Booth-Barbarin Excerpts from 6/20/07 deposition of Alfred Paulson Declaration of Beth E. Sund in Support of Plaintiffs' Motion For Order Imposing Discovery Sanctions

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