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

Filing 295

US District Court Middle District of Florida PLAINTIFFS' EXHIBIT Exhibit Number: 1 6 . 1 1 6:06md01769ACCDAB In Re: Seroquel Products Liability Litigation Date Identified: Date Admitted:

Exhibit 16.11

Jaffe.Jonathan
From: Sent: To: Gc: P e n n o c kPaul , Wednesday, June27,20075:05PM ([e-mail]), F r e dMagaziner [e-mail] ([e-mail]); Thomas Pirtle, Bailey Kenneth C a m pBailey([e-mail]); ([e-mail]); Trammell Fletch (tomp@lpm{riallaw.com); EdwardBlizzard ( f t r a m m e l l @ b p b l a w . c o m ) ; Scoft([e-mail]); Mike; Jaffe, Pederson, Allen Lawrence Gornick J. J o n a t h a nLaminack, ; Richard (richl@lpm{riallaw.com); N. ( l g o r n i c k @ l s k g - l a w . c o m ) ; Roth([e-mail]); P. Matthews David Larry (dmatthews@thematthewslawf irm.com) C o n t i n u i nlT Production g Failures

Subiect:

June7th. As youwill wroteus on June25thregarding agreements werereached or before on Y o u rco-counsel the that you in see fromreviewing below,I suggest havethemin Orlando the nextweekto answerfor thesebreaches our a g r e e m e n tandtheirgeneral s failure abideby theCMOsandtheirdiscovery to obligations. nowtellus thatit will 1 . LoadFiles Thecorrected filesareto be doneby July7th,perouragreement. load Yourpeople perhaps the which informed Courtandthis we happen July1Sth.That'snotacceptable. hadan agreement by We about m u s tbe doneby July7th. the 2. Metadataconsistency. can notverifyyourassertion it hasall beenconecteduntilwe receive loadfiles We that 1. u n d e rnumber above. Fields. Youwere MetaData 3. Swapped MetaData Fields You alsoviolated agreements to the Swapped the as supposed identify loadfilesthatwere incorrect to the within7 days. You'vestill notdonethat. your this, 4 . PageBreaks.Youwereto complete by July19th.Youhavealready this anticipatorily breached because you've people promises complete on a rolling not basis, this havenowtoldus perhaps 31st. Moreover, to July despite d o n eso. 5. ExcelSheets Your peoplehaveonly nowgivenus a timetable with respect the ExcelSheets.You'venowtold us to breach. of on t h a tit won'tbe doneby July31st,instead thegenerally understood ouraboutJuly7th. Thisis another you hadcreated 6. Objective Coding You agreedto tell us whether Objective Coding.You havetold us thatyou have. you you havecollected. get as W e wouldlikea listing thefields Please backto me by Friday to whether willgiveus of that the identity the fields. of 7 . Privilege Logs We haveno current dispute. phone withyouregarding assertion youdid notagree your to that 8 . Redaction Logs We needto haveoneadditional call this. havesome b/c 9. BlankDocuments Continue servethe "blanK'pagesthatyou say are beingproduced theyactually to this we blankpages, do notbelieve is a h e a d e r footer and andthustechnically haveto be produced. to the non-Excel As you documents June30th. by all " s m a lsubsef'asyouassert.Pursuant yourtimetable, willidentiry of the problematic l to Thisdate is acceptable we expectre-service the conected and of documents July7th,as agreed. by This issue. 1 0 . lP10Production. is no lonoeran to we 1 1 . ltem 12lCRF's:We don't*noJ*n"r rou'rereferring although thinkyou mightbe referring CANDA. Please to, we thatit was and to that by e x p l a i n we'llrespond yourassertion it was produced June8th. lf it is CANDA, agree produced. Language 1 2 . Foreign Documents: received harddrives. We the theyareall on there. 1 3 . 30b6depoExhibits: received harddriveandyourcommunication We a saying
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14. We haverejected Certification. are not agreeing the "keyword"searchof any kindand neverhave. Our the We to p o s i t i o n thishasbeenconsistent the beginning. wanteverything touches, on to from concerns relates or We that of Seroquelatypicalantipsychotic the injuries , and allegedto be causedby Seroquel any way. lf it meetsthe definition in underthe federalrulesand this court'sorders,thenwe wantit and are entitled it. lf you haveonlybeen to discoverable any by insisted we receive emails that searching your"keyterms"list,we havea big problem. Also,we haverepeatedly etc. sent by a custodian, deletedby him/herbut preserved somebody else'sfilesor computer, or otherdocuments in personis one of the 80 or not doesnot matter. We alsoare not limiting to AZ'semailaccount it that preservation Whether yearsago,Blackberry funded AZ. Now,andparticularly by was b u tanyemailaccount Service example noton a for fromany emailsystem. tf it exists,we want it. Also,youweresupposed makesurethat any information corporate to you gameof hidethe ballandI'mjustthankful that drives produced. essence, haveplayed longrunning In common be a we havea Magistrate Judgewho will understand what has beengoingon here. 1 5 . Databases. l'veaddressed in my prioremail. this Key. We did this as we agreedwe would- on time. 16 Production

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