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 5 6:06md01769ACCDAB In Re: Seroquel Products Liability Litigation Date Identified: Date Admitted:

Exhibit 16.15

Jaffe,Jonathan
From: Sent: To: Cc: Subject: Jonathan, As I understand, documents the identified you constitute by blankpageswhichwe stillintendto deliver. Specifically, tool. t h e s edocuments werefailures theTlFFing of by the module fireproperly, to usually excluding blankpageremoval pageswerediscovered our investigation our vendor's (and The substantive more blankand mismatched by specificallyas a resultof ScottAllen'sexample ) and are completed this redelivery. in Sincerely, Joe *--Original Message-*Flom: Jaffe,Jonathan ux.com] [mailto:jjaffe@weiEl SenH Thursday, July 19, 20075:48 PM To: Yeager,Joe Mike;Dennis Cc: Winchester, Tony; Freebery, James Duprg Andrew;LarryJ. Gornick; Pederson, Canty; J.; Kramer, Glenn Subject: RE:Replacement files Joe, J u s tto clarify, you meanthat thisjust represents blankpages documents we identified you, do on that to the yourvendor able determine? I understand below, scope otherdocuments you n o tthe ones was of that to As the problem not beenquantified Didthisinclude of the yet. t h a t mayor maynot be affected the same all by has you,Jim,andAndrew June fromChuck "Seroquel e x a m p l eIs Hunger wellincluding those Flash sentto 5th as on Reports" blanks? you, Thank Jonathan Jaffe From: Yeager, [mailto:JYeager@McCarter,com] Joe Sent Thumday, July 19, 20074:48 PM To: Jaffe,Jonathan Cq Winchester, Tony; Freebery, James Dupre,Andrew l.; SubjecB RE:Replacement files Jonathan, I apologize my lateresponse yourearliere-mail. Theday controlled as opposed my controlling I for me to it. to haverequested vendorto makeyour requested As our corrections the replacement production. for to file extracted with pagebreaksfor this production particular, text in franklyyou will receive extracted with page text media. breaksfor ALL files(including themon this production these)fasterthan it wouldtake us to include Yeager,Joe [[e-mail]] F r i d a y , 20,2007 July 9:57AM Jaffe,Jonathan WinchesterTony;Freebery, , Andrew JamesJ.; Dupre, RE: Replacement files

pertaining any additional represenb ln response yourquestion to this to blankpagedeliveries, production the pagesas identified ScottAllenat the 616meeVconfer. understand this I reproductiofor all mismatched n by that was morefullydiscussed someemailexchanges subject in AndrewDupreand PaulPennock 6129. on betlveen

Therewill be a separate reproduction blankpagesbut,that reproduction onlycosmetic it just removes for is blanksthat shouldbe blanksfromthe documents; doesnotadd or reorganize information. do notyet We it any h a v ea quantity that. on questions. As always,feelfreeto contactme withany additional Sincerely, Joe

---Original Message--Fromr Jaffe,Jonatha [mailto:[e-mail]] n S e n $ Thursday, 19,200710:14 July AM To: Yeager, Joe Cc: Pederson, Mike;LarryJ. Gornick; Canty;Kramer, Lenny Dennis Glenn;Femandez, SubjecB RE:Replacement files Joe, I wouldpreferthat we receive corrected anddat andtext filesthat corresponds the folders the lfp to y o ugaveto us.We do not needthe irnages re-provided with the corrected anddat files, will we as lfp pass overthem.We do needcorrected fileswith pagebreaks thatwe do not have re-import text so to multiple times andwe need agreed the uponfilenames. l f a newdrivecanget heretoday,thenthat routemightbe easiest, I A l s o , amstillunclear to whether will be receiving as we the additional fixesregarding blankpage issue f o r additional custodians yourearlier as email openthatpossibility, left you, Thank Jonathan Jaffe [e-mail]] From: Yeager, [mailto:JYea Joe S e n f i Thursday, 19,200710:01 July AM To: Jaffe,Jonathan Subject: Replacementles fi

Jonatlan, a follow-up as you fromyesterday's concerns, would prefer I re-sendnewdrive that a containing the only replacement andcorrected convention, provide with a list of thofilesthatarein factreplacements? files you lfo or I prefer former, thought would the but your seeking input Sincerely, made sense. Joe

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