Free Declaration - District Court of Arizona - Arizona

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EXHIBIT E I
Case 2:04-cv-00299-DGC Document 191-8 Filed 10/27/2005 Page 1 012

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Safia Anand I
From: Safia Anand
Sent: Monday, August 22, 2005 10:54 AM
To: '[email protected]'; '[email protected]'
Cc: Ira Sacks; [email protected]; '[email protected]';
'[email protected]'; '[email protected]'; 'joe|@joeIherz.com'; SatTa
Anand; '[email protected]'
Subject: Meadowlark Lemon
Florence and Anders,
· We are in receipt of your inadequate Expert Report. We demand that you submit a revised report, taking out
everything in the report that is contrary to Judge CampbelI's August 18 Order. More specifically, we demand that I
your expert take out all of the indications in her report as to the information she did not receive and/or information y
she still needs. Perhaps she did not have a copy of the August 18 Order when she drafted her report, but it clearly I
states that "the Court will [not] permit supplementation of the reportbased on information that could have been I
discovered during the year-plus time that preceded the expert deadline. Plaintiffs must provide full and complete 1
expert reports by August 19, 2005." lf you do not submit a revised expert report within the next week, we will I
make a motion to strike the report in part.
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In addition, I have attached a Notice of Deposition for Ms. Abalos for Monday, September 26, 2005. That is a firm
date in light of Ira's other obligations. We have noticed the deposition for your office; however, the location may be
changed if the Court Reporter that we get has a conference room that we can use.
We look fon/vard to receiving your revised Expert Report. ` I
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Abalos Notice of Abalos Notice of
I Deposition.pd... Dep Certitica... ‘ V ~ J
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Very truly yours,
Safia
Safia A. Anand, Esq.
Dreier LLP
Email: [email protected]
vwvw.dreierIlp.com . -
PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION
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confidential and exempt from disclosure under applicable law. lf you are not the intended recipient, or the
employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that
any dissemination, distribution or copying of this communication is strictly prohibited.
lf you have received this communication in error, please notify me immediately via e-mail at
[email protected]. Thank you.
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Case 2:04-cv-00299-DGC

Document 191-8

Filed 10/27/2005

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Case 2:04-cv-00299-DGC

Document 191-8

Filed 10/27/2005

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