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

Filing 416

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Dennis Canty From: Sent: To: Cc: Subject: Dupre, Andrew [ADupre@McCarter.com] Wednesday, August 15, 2007 2:40 PM McConnell, Stephen; Dennis Canty; sallen@crusescott.com; jjaffe@weitzlux.com; Munno, Thomas Torregrossa, Brennan; Winchester, Tony; Freebery, James J.; Yeager, Joe; Larry J. Gornick; Laura Brandenberg; kbailey@bpblaw.com; CBailey@bpblaw.com; MPederson@weitzlux.com; PPennock@weitzlux.com Meet/Confer Search Terms - Confirmation Hello All: This email is certain items today. While address those confirmation. meant to serve Plaintiffs' request for written confirmation of related to the new search term project that were discussed by phone a great many issues were discussed, I intend this email only to items for which Plaintiffs or AstraZeneca requested written 1. The documents residing at AstraZeneca's processing vendor that were not hit by the original search term list are not indexed. This was not part of the scope of work given to the vendor in the first instance - only documents deemed potentially relevant were sent to the end use vendor for indexing, production processing and coding. Therefore, searching for the new term list on which we are presently working to agree requires the vendor to search through text strings of the underlying documents, not an index. This explains why AstraZeneca has always given an estimate time for doing new searches as days or weeks rather than minutes. 2. The vendor is writing up a paragraph explanation of the deduplication process. I will forward it on when I receive it. 3. Plaintiffs have agreed to take the first crack at writing search terms that they actually want. For example, Plaintiffs will be responsible in the first instance for offering a term such as "diabet*", rather than "diabetic", if they want the search to reveal "diabetes". Similarly, Plaintiffs will identify which of their quote terms are really meant to be proximity searches and not verbatim term searches. This change largely eliminates the utility of my original proposal, because that proposal relied on lists of terms previously identified by Plaintiffs that do not necessarily represent what Plaintiffs really want. In other words, I anticipate having to rewrite the queries. 4. AstraZeneca has agreed to run all the acronyms as case insensitive. Plaintiffs have agreed to accept the large amount of false positives that this will surely hit, especially for words like "best". 5. AstraZeneca has agreed to get a proposed query for the remaining terms, which are those more complex search terms containing linkage devices, by Friday, August 17, 2007. Andrew S. Dupre, Esq. McCarter & English, LLP 405 North King Street 8th Floor Wilmington, Delaware 19801 1 Phone: 302-984-6328 Fax: 302-984-0311 This email message from the law firm of McCarter & English, LLP is for the sole use of the intended recipient(s)and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email(or helpdesk@mccarter.com) and destroy all copies of the original message. 2

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