FILED: NEW YORK COUNTY CLERK 05/05/ :30 PM INDEX NO /2016 NYSCEF DOC. NO. 185 RECEIVED NYSCEF: 05/05/2017. Exhibit A

Similar documents
Case 1:12-mc lk-CFH Document 37 Filed 01/15/13 Page 1 of 6

FILED: NEW YORK COUNTY CLERK 04/12/ :50 AM INDEX NO /2016 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 04/12/2017. Exhibit D

Application for Social Entrepreneurship Legal Services Clinic 1

FILED: NEW YORK COUNTY CLERK 09/08/ :05 PM INDEX NO /2015 NYSCEF DOC. NO. 443 RECEIVED NYSCEF: 09/08/2017. Exhibit A

Paul Alan Levy Thursday, January 18, :07 PM 'Van Shaw'

CLIENT INTAKE - CONFLICT OF INTEREST

Case 2:13-md CMR Document 85 Filed 05/06/14 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Stern & Eisenberg, PC

Shillinger-Bob. Dear Mr. Morris,

FILED: NEW YORK COUNTY CLERK 05/18/ :37 PM INDEX NO /2017 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 05/18/2017 EXHIBIT F

Despite our efforts to resolve your past due account, payment on this account has still not been made.

First Federal Savings Bank of Mascoutah, IL Agreement and Disclosures

Defendants. CHEN KASHER, an attorney duly licensed to practice law before the

Please give us till the end of this week to make amends, we promise we will have your funds forwarded to you.

Lusitania Savings Bank Retail Internet Banking Terms and Conditions

Please give us till the end of this week to make amends, we promise we will have your funds forwarded to you.

DISADVANTAGED BUSINESS ENTERPRISE PROGRAM. Unified Certification Program OKLAHOMA

Checklist for Rule 16(c) Pretrial Conference for Computer-Based Discovery

CUMBRE VISTA HOMEOWNERS ASSOCIATION, INC. RECORDS INSPECTION AND COMMUNICATIONS POLICY AND PROCEDURE. 1-Pl) ~ \ 1

Add/Drop Deadlines and Procedures. Fall 2017

mykpc Notifications Proactive Notifications

Case Evaluation Information EXPUNGEMENT

FILED: NEW YORK COUNTY CLERK 03/06/ :55 PM

DCU Guide to Subject Access Requests. Under Irish Data Protection Legislation

IMPORTANT INSTRUCTIONS:

Autofill and Other Disasters: The Ethics of Inadvertent Disclosures

Poly M Service - Terms & Conditions. (i) Big Envelope means a Poly M product of the dimensions set out in Clause 2.1(b);

Privacy & Cookie Statement

Customer Care Compliments & Complaints Policy and Procedures

Greater TEXAS Federal Credit Union 6411 North Lamar Blvd. Austin, TX (512) Toll Free: (800) Fax: (512)

Privacy Policy. Data Controller - the entity that determines the purposes, conditions and means of the processing of personal data

Meta-Discovery Presents Challenges for Producing Parties

T ERMS AND C ONDITIONS

Total Tax Group Privacy Notice


IAE Professional s (02)

CSBANK ONLINE ENROLLMENT FORM CITIZENS STATE BANK

Poly M Domestic Service - Terms & Conditions. Big Envelope means a Poly M Domestic product of the dimensions set out in Clause 2.

Mobley, Jenna W. Monday, February 23, :48 AM

Title: Personal Health Record Policy and Procedure. Manual: Health Information Management

Investigating Insider Threats

MANAGEMENT. The Language of Leadership. Fighting Water. CLM Internship Program. p.20. The Language of Leadership p 20.

complaint form ombudsman reference

STAUNING Credit Application Internet Sales Process with /Voic Templates to Non-Responsive Prospects 2018 Edition

RETURNS & PAYMENT / PRIVACY/ LEGAL NOTICE

Terms and Conditions between Easy Time Clock, Inc. And Easy Time Clock Client

First name: Address for correspondence (including postcode): Occupation: Daytime phone no: Mobile: Home phone no: address:

1900 M Street, NW, Ste. 250, Washington, D.C

Data Protection Policy

Five Ways that Privacy Shield is Different from Safe Harbor and Five Simple Steps Companies Can Take to Prepare for Certification

Terms and Conditions for Exam Registration at ESC

On Mon, Sep 28, 2015 at 5:01 PM, Sams, Savannah wrote:

Popmoney FAQs. What is Popmoney?

Lasting Power of Attorney for Health and Welfare A guide to filling in the form

TERMS AND CONDITIONS FOR THE USE OF THE WEBSITE AND PRIVACY POLICY

Website Privacy Policy

CONFLICT OF INTEREST SYSTEMS

Terms and Conditions for MPF e-statement/e-advice Service ( Terms and Conditions )

Monette Garcia AT&T Senior Sales Executive - Fiber Solutions Wireless: Beech Ave McAllen, TX 78501

Certified Addiction Recovery Coach Application

NEW Account - Electronic Transcript Requests Instructions for requesting Official Transcripts from Bethel University, Saint Paul, Minnesota.

Deloitte Audit and Assurance Tools

Health Services provider user guide

Online Ad-hoc Privacy Notice

NEW Account - Paper Transcript Requests Instructions for requesting Official Transcripts from Bethel University, Saint Paul, Minnesota.

1 Privacy Statement INDEX

APPOINTMENTS AND EVENTS

Getting Started with DonateNow

Milk Support Service Level Agreement

Massage therapy user guide

Managing Your Record Retention Policy Safely

The JACK S SMALL ENGINES BLACK FRIDAY - CYBER MONDAY GIVEAWAY OFFICIAL RULES

PPR TOKENS SALE PRIVACY POLICY. Last updated:

MICHIGAN INTERNATIONAL SPEEDWAY KIDS CLUB PRIVACY POLICY

A GUIDE TO CYBERSECURITY METRICS YOUR VENDORS (AND YOU) SHOULD BE WATCHING

Can we please set up a conference call for Nevadaworks to provide clarification to this question?

Privacy Shield Policy

VETS FIRST CHOICE PRIVACY POLICY FOR PARTICIPATING VETERINARY PRACTICES

Frequently Asked Questions

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Registration. Adding Accounts. How do I sign up for this service? The sign-up process for this service is quite simple.

1 About GfK and the Survey What are personal data? Use of personal data How we share personal data... 3

Online Statements Disclosure

SeelogicMail Terms and Conditions

Please process as per my usual instructions.

Complaint Handling Procedure

Attached is a copy of Underwriters Laboratories UL , Standard for Safety Factory-Made Air Ducts and Air Connectors.

REMOTE VIDEO DEPOSITIONS

Acceptable Use Policy

PRIVACY POLICY BACKGROUND:

Identity Theft Policies and Procedures

FILED: NEW YORK COUNTY CLERK 06/14/ :18 PM INDEX NO /2017 NYSCEF DOC. NO. 272 RECEIVED NYSCEF: 06/14/2018

AN INMATE S GUIDE TO ADMINISTRATIVE REMEDY REQUESTS AT FEDERAL PRISONS

PRIVACY NOTICE STORM RECRUITMENT UNIT 11, 2 ND FLOOR CHARLESLAND CENTRE, GREYSTONES, CO. WICKLOW 1. INTRODUCTION

Domain Hosting Terms and Conditions

How to Reserve a Practice Room on EMS.

RE: Potential appeal involving James Richard Bruvall ( Alberta Ltd.) and BC Society of Prevention of Cruelty to Animals

USER CORPORATE RULES. These User Corporate Rules are available to Users at any time via a link accessible in the applicable Service Privacy Policy.

NASD REGULATION, INC. OFFICE OF HEARING OFFICERS

DEF1816. Case 2:13-cv Document Filed in TXSD on 11/19/14 Page 1 of 6. 2:13-cv /02/2014

Transcription:

Exhibit A

From: Sent: To: Cc: Subject: Kry, Robert <rkry@mololamken.com> Friday, May 05, 2017 1:45 PM Gabriel Soledad; Daniel Pulecio-Boek; Juan Morillo; Derek Shaffer; Valerie Ramos; 'tcgreen@sidley.com'; 'mhopson@sidley.com'; 'pzidlicky@sidley.com'; 'mcolonbosolet@sidley.com'; 'tlosseaton@sidley.com'; 'Aravand, Pouneh (paravand@sidley.com)' Molo, Steven; Ortiz, Jessica; Weinstein, Lauren RE: Rimsa v. Espinosa, No. 655112/2016 - deposition notice Gabe, We proposed a time for the call Monday. Please let us know if you re available. There is no reason the call cannot go forward then. Beyond that, as I said, we will respond to the substance of your email separately. Robert From: Gabriel Soledad [mailto:gabrielsoledad@quinnemanuel.com] Sent: Friday, May 05, 2017 12:08 PM To: Kry, Robert; Daniel Pulecio-Boek; Juan Morillo; Derek Shaffer; Valerie Ramos; 'tcgreen@sidley.com'; 'mhopson@sidley.com'; 'pzidlicky@sidley.com'; 'mcolon-bosolet@sidley.com'; 'tlosseaton@sidley.com'; 'Aravand, Pouneh (paravand@sidley.com)' Cc: Molo, Steven; Ortiz, Jessica; Weinstein, Lauren Robert, Please let us know if you are going to postpone the deposition. If not, we feel obliged to raise this with the Court today, and ask that you provide a time when one of the many lawyers on your side can join. Please advise asap. Gabe From: Kry, Robert [mailto:rkry@mololamken.com] Sent: Friday, May 05, 2017 12:02 PM To: Gabriel Soledad <gabrielsoledad@quinnemanuel.com>; Daniel Pulecio-Boek <danielpulecioboek@quinnemanuel.com>; Juan Morillo <juanmorillo@quinnemanuel.com>; Derek Shaffer <derekshaffer@quinnemanuel.com>; Valerie Ramos <valerieramos@quinnemanuel.com>; 'tcgreen@sidley.com' <tcgreen@sidley.com>; 'mhopson@sidley.com' <mhopson@sidley.com>; 'pzidlicky@sidley.com' <pzidlicky@sidley.com>; 'mcolon-bosolet@sidley.com' <mcolon-bosolet@sidley.com>; 'tlosseaton@sidley.com' <tlosseaton@sidley.com>; 'Aravand, Pouneh (paravand@sidley.com)' <paravand@sidley.com> Cc: Molo, Steven <smolo@mololamken.com>; Ortiz, Jessica <JOrtiz@mololamken.com>; Weinstein, Lauren 1

<lweinstein@mololamken.com> Gabe, This afternoon does not work for our side. Please let us know your availability for a call at 1 p.m. on Monday. We will respond separately to the other points in your email. Robert Robert K. Kry 600 New Hampshire Ave., NW Washington, DC 20037 T: (202) 556-2011 M: (202) 631-1067 F: (202) 536-2011 rkry@mololamken.com www.mololamken.com From: Gabriel Soledad [mailto:gabrielsoledad@quinnemanuel.com] Sent: Friday, May 05, 2017 11:07 AM To: Kry, Robert; Daniel Pulecio-Boek; Juan Morillo; Derek Shaffer; Valerie Ramos; 'tcgreen@sidley.com'; 'mhopson@sidley.com'; 'pzidlicky@sidley.com'; 'mcolon-bosolet@sidley.com'; 'tlosseaton@sidley.com'; 'Aravand, Pouneh (paravand@sidley.com)' Cc: Molo, Steven; Ortiz, Jessica; Weinstein, Lauren Counsel, We have not heard back regarding your availability to call the Court. We would like to resolve these issues today. Please let us know when today you are available to call the Court. Gabe From: Gabriel Soledad Sent: Thursday, May 04, 2017 2:23 PM To: 'Kry, Robert' <rkry@mololamken.com>; Daniel Pulecio-Boek <danielpulecioboek@quinnemanuel.com>; Juan Morillo <juanmorillo@quinnemanuel.com>; Derek Shaffer <derekshaffer@quinnemanuel.com>; Valerie Ramos <valerieramos@quinnemanuel.com>; tcgreen@sidley.com; mhopson@sidley.com; pzidlicky@sidley.com; mcolonbosolet@sidley.com; tlosseaton@sidley.com; Aravand, Pouneh (paravand@sidley.com) <paravand@sidley.com> Cc: Molo, Steven <smolo@mololamken.com>; Ortiz, Jessica <JOrtiz@mololamken.com>; Weinstein, Lauren <lweinstein@mololamken.com> 2

Counsel, We take allegations of witness tampering extremely seriously, just as we re sure you do. Accordingly, we expect that you will produce information well beyond what you ve identified in support of those allegations, and that you will do so in advance of any call with the Court. Please rest assured that none of us at Quinn Emanuel has had anything to do with any witness tampering to which you allude. Nor have we heard of any such activity prior to your email. Nor do we have any interest in preventing Ms. Huerta s deposition. To the contrary, we intend to cross-notice it. Consistent with that, we re trusting that you ll be affording us equal time to pursue our own questions. If not, please let us know so we can take this issue up with the Court alongside the others. To reiterate, all we re asking is that we be permitted to adequately prepare for Ms. Huerta s deposition, and, correspondingly, that we have the necessary documents and opportunity to prepare in advance of it. If anything is delaying her deposition, therefore, it is your continuing delays with production delays that we have been bringing to your attention and urging you to rectify since last year, while noting, e.g., that your delays in producing documents would delay our preparations for depositions. On January 20, as part of your initial search term and custodian proposal, you agreed to search and produce Ms. Huerta s custodial files. Also on that date, you indicated that you intended to search her files exclusively for documents that included the term double paperwork in English and in Spanish, and other references to such alleged documents. More than three months later, and after repeated requests from us, however, you still have failed to complete your production of Ms. Huerta s custodial documents. After all of your delays, we re asking to be afforded just two weeks for our preparation, from the date you complete your production of her custodial documents to when the deposition proceeds. You must recognize that it typically takes roughly two to three days just to upload documents into our review platform such that we can then start reviewing them. Your proposal does not account for that, much less enable us to follow-up on any deficiencies we may identify in your production. You are denying us the time we need to review your latest production of Ms. Huerta s custodial files and develop our lines of inquiry in time for her upcoming deposition, which we recognize may afford us our only chance to question her (consistent with concerns you ve long expressed about witness availability). And you are rejecting our proposal to have Ms. Huerta s deposition proceed in proximity to that of Raul Nava, as noticed for May 26. Finally, it is striking that you are invoking unsubstantiated allegations of witness tampering while refusing to provide basic information about what compensation and benefits Ms. Huerta is being paid by Teva. In our respectful view, Teva cannot avail itself of Ms. Huerta s testimony while blocking discovery into the financial strings Teva is holding over her. We agree that the Court should resolve our differences in these respects and will be available for a call at your convenience. Gabe From: Kry, Robert [mailto:rkry@mololamken.com] Sent: Thursday, May 04, 2017 10:52 AM To: Daniel Pulecio-Boek <danielpulecioboek@quinnemanuel.com>; Juan Morillo <juanmorillo@quinnemanuel.com>; Derek Shaffer <derekshaffer@quinnemanuel.com>; Gabriel Soledad <gabrielsoledad@quinnemanuel.com>; Valerie Ramos <valerieramos@quinnemanuel.com>; tcgreen@sidley.com; mhopson@sidley.com; pzidlicky@sidley.com; mcolon-bosolet@sidley.com; tlosseaton@sidley.com; Aravand, Pouneh (paravand@sidley.com) <paravand@sidley.com> Cc: Molo, Steven <smolo@mololamken.com>; Ortiz, Jessica <JOrtiz@mololamken.com>; Weinstein, Lauren 3

<lweinstein@mololamken.com> Subject: Rimsa v. Espinosa, No. 655112/2016 - deposition notice Counsel, We plan to proceed with Ms. Huerta s deposition on the originally scheduled date of May 12th. The urgency of the timing relates to our serious and well-grounded concerns about witness tampering in this case. We received information yesterday evening that a former Rimsa employee contacted a colleague of Ms. Huerta s at the company attempting to obtain Ms. Huerta s home address. This is someone who has no personal relationship with Ms. Huerta, and it is difficult to imagine a legitimate reason for the inquiry. This follows multiple other incidents over the past month in which another former Rimsa employee s lawyer has attempted to contact Ms. Huerta. We expect to produce some of the documents identified by our most recently agreed-upon search terms for Ms. Huerta this Friday, May 5, and the remaining documents identified by those terms next Monday, May 8, or at the latest, Tuesday, May 9. We have already produced the documents we currently plan to use in the deposition. If we decide to add any documents from these forthcoming productions, we will specifically identify those documents for you in advance of the deposition. The other information you have asked for is not relevant to the propriety of proceeding with the deposition at this time. Please let us know when you re available for a call with the court to discuss these matters. Robert Robert K. Kry 600 New Hampshire Ave., NW Washington, DC 20037 T: (202) 556-2011 M: (202) 631-1067 F: (202) 536-2011 rkry@mololamken.com www.mololamken.com This e-mail may contain attorney work product, privileged and/or confidential information. It is intended to be subject to the Attorney Client privilege. It is intended only for the original recipients, and no other person is authorized to receive it. Please do not copy or forward this e-mail without the consent of the author. If you have received this e-mail in error please delete it immediately from your system and contact the author. Molo Lamken LLP is a limited liability partnership formed under the laws of New York and the liability of its partners is limited accordingly. The names Molo Lamken and MoloLamken shall refer to Molo Lamken LLP. This e-mail may contain attorney work product, privileged and/or confidential information. It is intended to be subject to the Attorney Client privilege. It is intended only for the original recipients, and no other person is authorized to receive it. Please do not copy or forward this e-mail without the consent of the author. If you have received this e-mail in error please delete it immediately from your system and contact the author. Molo Lamken LLP is a limited liability partnership 4

formed under the laws of New York and the liability of its partners is limited accordingly. The names Molo Lamken and MoloLamken shall refer to Molo Lamken LLP. This e-mail may contain attorney work product, privileged and/or confidential information. It is intended to be subject to the Attorney Client privilege. It is intended only for the original recipients, and no other person is authorized to receive it. Please do not copy or forward this e-mail without the consent of the author. If you have received this e-mail in error please delete it immediately from your system and contact the author. Molo Lamken LLP is a limited liability partnership formed under the laws of New York and the liability of its partners is limited accordingly. The names Molo Lamken and MoloLamken shall refer to Molo Lamken LLP. 5