EFTA00029487.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: ' 
(USANYS)"  
To: ' 
(USANYS)"  
Subject: RE: Phone Call Follow-Up 
Date: Fri, 30 Oct 2020 20:15:45 +0000 
Inline-Images: image001.png 
Not good. 
From: 
(USANYS) <
> 
Sent: Friday, October 30, 2020 2:45 PM 
To: 
(USANYS) 
Subject: FW: Phone Call Follow-Up 
We will most likely not meet the November 9 deadline. 
From: 
(USANYS) 
Sent: Friday, October 30, 2020 2:41 PM 
To: 
(USANYS) a; 
Subject: RE: Phone Call Follow-Up 
(USANYS) 
Thanks, 
The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I 
realize that this is a big project and that there's only so much that can be done, but it poses almost insurmountable timing 
hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this 
one included, that eats up a huge chunk of the time we have available to produce discovery. 
We'll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher 
level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing 
this deadline. 
From: 
(USANYS) <
Sent: Friday, October 30, 2020 12:51 PM 
To: 
(USANYS) 
Subject: FW: Phone Call Follow-Up 
(USANYS) 
Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is 
still being imaged. Then it gets marked. Then copied to us. I have spoken to 
He thinks it is not possible to 
meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion 
might be possible. 
From: Koontz, Nicholas [US] < 
Sent: Friday, October 30, 2020 12:25 PM 
To: 
(USANYS) a> 
Cc: 
(USANYS) [Contractor] <
> 
Subject: Phone Call Follow-Up 
Good Afternoon M: 
EFTA00029487


Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via 
FedEx with the following production…
Open in the interactive archive →