City of Winter Haven v. Cleveland Indians Baseball Company Limited Partnership
From: Sent: To: Cc: Subject: Attachments: Dennis Canty Monday, August 06, 2007 4:44 PM 'email@example.com'; 'firstname.lastname@example.org'; 'email@example.com'; 'NMalik@faegre.com' Larry J. Gornick; Debra DeCarli; Laura Brandenberg; Leah Sabel; Beth Sund September Disclosures Letter to L. Gornick and L. Roth enclosing September Disclosures.pdf
Dear Counsel: This is plaintiffs' attempt to meet and confer concerning the September disclosures referenced in the attached letter. Pursuant to Mr. Magaziner's representations at the July 27, 2007 MDL hearing, and the Court's August 3, 2007 Order, these disclosures were to be made in electronic form. Because they are not, and because plaintiffs do not therefore have the same ability to manipulate and search the data as do defendants, these are tantamount to no disclosures at all. Until the disclosures (particularly the attached call notes and IMS data) are made in a form suitable for analysis, plaintiffs' time to designate a sales representative pursuant to CMO4 will not begin to run. Please advise as to when we can expect to receive compliant disclosures. We ask that transmission of all future or supplemental disclosures include the addressees on this email. Thank you. Dennis J. Canty Levin Simes Kaiser & Gornick LLP 44 Montgomery Street, 36th Floor San Francisco, CA 94104 Tel: 415/273-8138
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