American Airlines Inc v. Travelport Limited et al

Filing 311

NOTICE to Court Pursuant to Order Regarding Plaintiff's Motion to Compel Production of Documents Wrongfully Withheld Under the Guise of Privilege filed by American Airlines Inc (Garcia, Yolanda)

200 Crescent Court, Suite 300
Dallas, TX 75201-6950
[phone] tel
[phone] fax

April 30, 2012

Yolanda C. Garcia
214-746-8134
[e-mail]

Hon. Jeffrey L. Cureton
U.S. Magistrate Judge
United States District Court
Northern District of Texas
501 W. 10th Street
Room 520
Fort Worth, Texas 76102-3673
Re: American Airlines, Inc. v. Travelport Ltd., et al., No. 4:11-CV-244-Y (N.D. Tex.)
Dear Judge Cureton:
I write on behalf of Plaintiff American Airlines, Inc. (“American”) with respect to its Motion to Compel
Production of Documents Wrongfully Withheld under the Guise of Privilege by the Travelport
Defendants filed on April 6, 2012 [Dkt. 290] (the “Motion”), and the Court’s order thereon entered on
April 16, 2012 [Dkt. 299] (the “Order”).
The Court’s Order required American, on the one hand, and Travelport LP and Travelport Limited
(collectively, “Travelport”), on the other hand, to confer and try to resolve American’s concerns with
Travelport’s privilege logs between themselves, and directed American to notify the Court by April 30,
2012 if the Motion should be rendered moot.
In accordance with the Order, the parties have conferred regarding American’s Motion. As a result of
the Court’s Order and the parties’ efforts, as of today, Travelport has committed to produce over 1,000
documents from its privilege log, including 118 of the 325 exemplar documents identified by American.
Travelport has not yet produced any of these documents, but says it will do so by May 1, 2012.
Additionally, just 3 business days ago, on April 25, 2012, Travelport produced a new “revised” privilege
log, containing over 17,800 entries.
The Court ordered the parties to attempt to resolve the discovery dispute without Court intervention.
(See Order at 1.) American has not had the opportunity to scrutinize Travelport’s revised privilege log
or the documents Travelport intends to produce. Further, American and Travelport are currently
conferring as to whether Travelport will voluntarily review the remainder of its log, as requested by
American in the relief sought in its Motion. Thus, the Motion has not been resolved at this time, but the

US_ACTIVE:\43990324\04\14013.0135

Hon. Jeffrey L. Cureton
April 30, 2012
Page 2

parties are working diligently resolve the dispute pursuant to Dondi Properties Corp. v. Commerce
Savings & Loan Assoc., 121 F.R.D. 284 (N.D. Tex. 1988) (en banc).
Please let us know if you have any questions or concerns.
Respectfully submitted,
s/Yolanda Cornejo Garcia
Yolanda Cornejo Garcia

cc: Counsel of Record

US_ACTIVE:\43990324\04\14013.0135