Wed 30 Mar 2022 16 56 57 0000 Zeeman Discovery 17Fdbc25 2¶

Eric,

Thanks for your call.  As we discussed, attached are our initial drafts of the responses to interrogatories and requests for production.  You will note our comments in the margins regarding which requests pertain to the defense of the case-in-chief vs. the counterclaims.  We will take lead on requests pertaining to defense of case-in-chief and will defer to you to handle finalizing/crafting responses to requests dealing with Ms. Zeeman's counterclaims.

Also attached is Ms. Zeeman's notes/additions to our initial draft of responses to interrogatories.  Ms. Zeeman has done a nice job organizing the responses and the documents responsive to each RPD in the dropbox link.  We will be using Ms. Zeeman's most recent draft as our master copy.

I look forward to hearing from you once you've had a chance to review.

Thanks.


Sally Monico
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