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

Filing 416

Dennis Canty
From: Sent: To: Cc: Subject: Dennis Canty Monday, August 20, 2007 5:30 PM McConnell, Stephen; 'Balakhani, Elizabeth'; 'Prince, Shane'; Dupre, Andrew Larry J. Gornick; [e-mail]; [e-mail]; Pederson, Mike; Pennock, Paul; [e-mail]; '[e-mail]'; 'Holly Wheeler'; Jaffe, Jonathan Status of investigations

Steve and Andrew ­ As Andrew wrote on August 18, we do find it hard to believe that "AstraZeneca would ignore the issues raised at the sanctions hearing" and expect that AstraZeneca has been "conducting audits related to the issues." This is another request for an update on AstraZeneca's various investigations into the lack of voicemail attachments, fax attachments, video attachments and documents containing "track changes." Though seemingly omitted from the list of items in Section III A B 1 c of the Joint Status Report and Agenda, we do intend to review with the Court on Wednesday the status of AZ's investigation into the "track changes" issue. It appears that the document you offered at the hearing (Defendants' Exhibit 66) was originally a hard copy document. Has AstraZeneca's continuing investigation turned up any evidence whatsoever that it has produced to plaintiffs the "track changes" contained in electronic documents? Please advise. Dennis J. Canty Levin Simes Kaiser & Gornick LLP 44 Montgomery Street, 36th Floor San Francisco, CA 94104 Tel: [phone]

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