Advanced Water Technologies Inc. v. Amiad U.S.A., Inc.

Filing 85

ORDER granting 83 Letter Motion for Discovery. SO ORDERED. (Signed by Judge Lewis J. Liman on 6/29/2020) (va)

Case 1:18-cv-05473-LJL Document 83 Filed 06/29/20 Page 1 of 1
85
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6/29/2020

RONALD FRANCIS
ATTORNEY-AT-LAW

30 BROAD STREET, 37TH FLOOR
NEW YORK, NY 10004
[phone]
FAX [phone]
EMAIL [e-mail]

June 29, 2020
Via ECF
The Honorable Lewis J. Liman
United State District Judge
Southern District of New York
500 Pearl Street, Room 710
New York, NY 10007
Re:
Dear Judge Liman:

Advanced Water Technologies, Inc. v. Amiad U.S.A., Inc.
Docket No. 1:18-cv-05473(LJL)

I represent plaintiff Advanced Water Technologies, Inc. (“AWT”) in the abovereferenced action. On June 27, 2020, this Court ordered AWT to submit a draft interrogatory to
the Court for it to review and approve. The interrogatory addresses the search terms Amaid
applied to collect documents in response to AWT’s document requests. Attached as Exhibit 1 is a
draft of AWT’s Third Set of Interrogatories Pursuant to the Court’s June 27, 2020 Order. We
will await the Court’s approval before we serve this interrogatory on defendant.
Thank you for your consideration of this matter.
Respectfully submitted,
Ronald Francis

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------x
ADVANCED WATER TECHNOLOGIES INC.,

Case No. :1:18-cv-05473-LJL
PLAINTIFF’S DRAFT THIRD
SET OF INTERROGATORIES

Plaintiff,
-againstAMIAD U.S.A., INC.,
Defendant.
---------------------------------------------------------------x

Plaintiff Advanced Water Technologies Inc. (“AWT) requests, pursuant to Rule 33 of the
Federal Rules of Civil and the Court’s June 27, 2020 Order, that defendant Amiad U.S.A., Inc.
(“Amiad”) answer the following interrogatory, under oath, with five (5) business days of it being
served upon the undersigned to the law offices of Ronald Francis, located at 30 Broad Street, 37th
Floor, New York, NY 10004.
This Interrogatory should be read, interpreted, and responded to in accordance with the
instructions and definitions set forth in the Federal Rules of Civil Procedure and Local Civil
Rules. Plaintiff reserves its right to serve supplemental interrogatories at a later date.

INTERROGATORY
1. State whether Amiad used search terms or filters to search Amiad’s electronic stored
information (“ESI”) or other data in Amiad’s possession, custody, or control to identify ESI
responsive to AWT’s document requests served on February 28, 2020. If so, identify each
source of ESI searched, including email accounts, computer hard drives, or other storage media,
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and identify the search terms and filters applied during the search of ESI.

Dated: New York, NY
June 29, 2020
RONALD FRANCIS, ESQ.
By: Ronald Francis
Ronald Francis
Attorney for Plaintiff
30 Broad Street, 37th Floor
New York, NY 10004
[phone]
[e-mail]

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