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 . 0 5 6:06md01769ACCDAB In Re: Seroquel Products Liability Litigation Date Identified: Date Admitted:

Exhibit 16.05

Jafre,Jonathan
Frcm: Sant: To; Cc: Jaffe,Jonathan Friday, February 02,200712:26 PM Miilcr,Rodney K.' ([e-mail]); Camp Bailey([e-mail]); Trammll Fletdl Jensen, KeithM. ([e-mail]); Driscoll ([e-mail]); John Kenneth ([e-mail]); Bailey Kenneth Smith(KSmith@A\tt W. Lany S-LAW.corn); Roth (LROTH@rotNa,v.com); LawreneJ. Gornick Mike {lgomid(@lskg-la.r.corn); Penin (MPenin@bpbla$/.com); Pederson, Mike; Pennook, Pete Paul; Schnekler ([e-mail]); Laurie SchulE, RE:Document Prcduction Responses

$ublect:
Rodney,

Basedon our understanding you eithercannotget the SourceLocation, cannotget it without that or extraordinary effort, we wouldliketo startproduction. mayleavethisfield,blank,in the metadata. You Pleaselet us knoar howsoonwe can expectfiles,andfor whichcustodians. Bestregards, Jonathan Jaffe

Fronu Miller, Rodney [mailto:rkmilter@$dby.com] K. Sent: Thursday, February ?0072:00pM 01, To: Jaffe,lonatran Subjttcb RE:Docunent Producton Response Ionathan, As I explained to you on the phone, during the course of drafting CMO2, we discussedwith our vendor the metadatafields that would be available to us to produce. Although the sourcelocation was identified as an available field, it was not populated with data -- instead, information pertaining to the sourceis made available to you in the File Location and SourceName metadatafields. Accordingly, when documents are produced, the sourcelocation field will be blank (alternatively, we can drop thatfield from the metadata produced to you). Pleasediscusswith your team, and let me know if we can begin preparing documents for production under these parameters. Thanks, Rodney

From: Jaffe,Jonathan lmaifto:iiaffe@weitrtuxcom] Sen$ThuMan Febnnry 2007 01, 7:01AM Tol Milfer, RodneyK. SUHech RE:Doqlment ProdrdionRcporses Rodney,

Whendo you thinkthat youwill knowabout#5? Thanks, Jonathan Jaffe

From:Mlller, Rodney [maifto:[e-mail]] K. Sent TuesGy, January n,2W7 4:56PM To: Jaffe,Jonathan SubJecE Document RE: Producti$r Responses Jonathary Additional follow up. With respectto no. 4, a7-Bit text file is a text file that results when a user opens a non-text document tfuough a text application. For example,if someoneopened a JPEGimage file in Wordpad, Wordpad may be able to read some text in the ]PEG. If the user were to save the fPEG as a text file, the result is a 7-bit text file. We're still looking into no.5. - Rodnev

Frcm: Jaffg Jonathan lmailb:i][e-mail] To: Miller, K Rodney SubFce RE:DocurntBodudiont{esponses you Thank Rodney. #4 and#5areholding upnow Only us

Frcm;Miller, K. Rodney [mailtc:[e-mail]] SenkTuesday, 30, 4iZ6Pt4 January 2007 To: Jaffe, Jonathan Subiect Doorment Pnrduction Responses jonathan, The following provides a statuson your questionsfrom earlier today. I will update this e-mail,and provide you estimates timing of production, assoonas I leam more. on (1)SampledocumentAZ/SER 233, The atbachment this documentwas not produced to as part of the sampleproductio+ but the control number for the documentapplim to an existingdocumentthat will be producedin the courseof the production. (2) The U1/7801date. This "date"is usedasa default to indicate documentsthat do not have a date. This date typically appliesto paper documentsthat lack a date printed on the page. Whereportions of a date are available* for example,the year - that information wilt be included in the datefield.

to each document's conkol number a prefix of uEn electronic document and nPu for for

(3) SampledocumentAZ/SER474is a paper documentthat was scanned.We will add

paper document. (4) %Bit Text. This designationtypically is given to simple text files. I am continuing to investigateto get a final answer,and will respondassoonasI know more. (5) Blank "locatron"field. As with no. 4, I am continuing to investigatg and will respondonceI know more. Thanks, RodnevK. Miller SIDLEYAUSTIN LLP One South Dearborn Chicago,IL 60503 (312)85360911

(312) 70S6 853 FAX
rkmiller@sidley,com
S i d l e y Austin L5:24:00: LLP mail server rnade the following annotatj-ons on 01/30/07'

I R S Circular 230 Discfosure: To comply with certain U.S. Treasury regulations, we inform you t h a t , unless expressly stated otherwise, any U.S. federal tax advice c o n t a i - n e d 1n this c o n u n u n i c a t i o n , including to be used, attachmenls, was not intended or written a n d cannot be u s e d , by any taxpayer for the purpose of avoiding any penaltles that may be i m p o s e d on such t a x p a y e r by the TnternaL Revenue Service. In addition, if any such tax a d v i c e is used or referred t o by other parties in promoting, marketing or recomnending any partnership o r other entityr i n v e s t n e n t plan or affanqement, then (i) the advice should be construed as written in connection w i t h the promotion or marketinqi by others of the transaction(s) or matter(s) a d d r e s s e d in this c o r u n u n i c a t i o n and (ii) tfre taxpayer should seek advice based on the taxpayer's particular c i r c u m s t a n c e s from an independent tax advisor*********************************jr*******************************************

*********************** that is T h i s e-malL is sent by a 1aw firm and may contain information p r i v i L e g e d or confidentia]. please delete the e-mail and any I f you are not the intended recipient, a t t a c h m e n t s and notifv us i n a n e d i a tel y. *****************************************************************************
**** ******r.** ********* *

S i d l e y Austin

LLP mail server made the following
467

annotations

on 01/30/07'

15:53:20: