Free Declaration in Support - District Court of California - California


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Date: February 6, 2008
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Case 3:07-cv-03758-SC

Document 114-9

Filed 02/06/2008

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Case 3:07-cv-03758-SC

Document 114-9

Filed 02/06/2008

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U.S. Department of Justice
Civil Division

Washington, D. 20530 C.

January 15,2008

Mr. Gordon Erspamer Morrison & Foerster, LLP 101 Ygnacio Valley Rd., Suite 450 Walnut Creek, Calif. 94596-8 130

RE:

Veterans for Common Sense v. Mansfield, (N.D. Cal. No. C-07-3758)

By: Regular mail and E-mail [[email protected]] Dear Gordon: With the Court's Order of January 10,2008 lifting the stay on discovery, defendants would like to schedule a teleconference to meet and confer with plaintiffs on a number of discovery issues presented by plaintiffs' outstanding discovery requests. At the outset, we strongly urge plaintiffs to revisit and narrow their discovery requests and particularly their 191 requests for production of documents, since, as currently drafted these requests will impose an extensive administrative burden on the Department of Veterans Affairs (VA). See Declaration of Thomas Bowman.

1. Defendants will attempt to respond to plaintiffs' 191 Requests for Production of Documents on or before February 11,2008, 30 days from the Court's Order lifting the stay. Depending on outcome of our meet-and-confer discussions, the volume of responsive material and the resources available to the VA, after an initial production on that date, we anticipate a rolling production of documents over an extended period. We are open to any suggestions as to the order in which categories of material will be produced. Additionally, defendants will not be able to produce documents subject to the Privacy Act until the Court has entered an appropriate Order under 5 U.S.C. 5 552a(b)(ll).
2. On the question of depositions, plaintiffs' November 2,2007 Deposition notices are not valid since plaintiffs did not consult with defendants' counsel about scheduling these dates as

Case 3:07-cv-03758-SC

Document 114-9

Filed 02/06/2008

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