City of Winter Haven v. Cleveland Indians Baseball Company Limited Partnership
From: Sent: To: Cc: Subject: Attachments: Importance: Kaufman, Daniel [firstname.lastname@example.org] Friday, August 24, 2007 4:53 PM MPederson@weitzlux.com; Dennis Canty; email@example.com Kerns, Kevin FW: Email re meet and confer (attaching chart) Book1.xls High
Gentlemen, Per our telephone conference yesterday to meet and confer with our respective IT experts regarding promotional materials and the eSTaR database, below are our agreements and the additional information you requested:
We agreed to produce a full extraction, in native Excel format, of the non-privileged Seroquelrelated data from eSTaR after completing a review of potentially-privileged data and you indicated this was an accpetable manner of proceeding. We agreed to provide you with our working copy of a spreadsheet today, containing a limited number of fields, to immediately assist you in locating promotional materials referenced in call notes and you indicated this was an accpetable manner of proceeding. This spreadsheet is attached hereto. As we discussed, the attached spreadsheet is attorney work product reflecting the key information from the eSTaR database for Seroquel-related items, but excluding any fields that might contain privileged information. We removed comment fields from this chart, as they require additional review to redact privileged information. We agreed to identify the eSTaR data that we would need to review prior to production. o We will need to review comment fields to redact privileged information. o We will need to review spreadsheets reflecting information about non-branded CNS and managed market items to eliminate items that are not related to Seroquel. o We will need to review drafts contained in eSTaR to redact privileged information. We offered to quickly provide all Seroquel-related eSTaR data, excluding drafts, comments, and non-branded CNS and managed market pieces and to supplement this production with non-privileged drafts, comments, and non-branded CNS and managed market pieces upon completing our review thereof. You indicated that you would prefer to receive all of this information at one time, after we complete our review of the potentially-privileged data. After consulting with our vendor, we are unable to identify a method for redacting data in a native Excel production. If you are able to suggest a method to accomplish this task, please do so. Unless you can suggest a workable alternative, we propose the following: o We will first produce a full extraction, in native Excel format, of the non-privileged Seroquel-related data from eSTaR, excluding any fields or data that would possibly contain privileged information. o We will then provide a redacted spreadsheet in Tagged Image File Format (TIFF) containing the PRA number, title, and non-privileged comments regarding every Seroquel-related item in the eSTaR database. o We will also create TIFFs of the attachments maintained in the eSTaR database so that we can redact any privileged information contained therein. We agreed to arrange for a meet and confer regarding MarketPro and to arrange for technically sophisticated representatives with full knowledge of this database to participate in this call and you indicated this was an accpetable manner of proceeding. We are working to
identify the appropriate AstraZeneca personnel to participate in this call and will contact you regarding scheduling as soon as possible. We did not agree to produce any materials from other databases unrelated to our PRA production.
Please let me know if I missed anything and whether you have any comments or questions about our proposed plan of action. Thank you. Daniel S. Kaufman Dechert LLP A Pennsylvania Limited Liability Partnership direct: +1.212.698.3687 fax: +1.212.698.3599 firstname.lastname@example.org www.dechert.com
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