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Record

Draft: efta02805304

Exhibit A

From: Sandra Perkins Sent: Thursday, April 27, 2017 4:12 PM To: 'Maya_H_Nuland@nysd.uscourts.gov' Cc: 'SweetNYSDChambers@nysd.uscourts.gov' Subject: RE: v. Maxwell, Case No: 15-cv-07433-RWS Attachments: 2017.04.03 Defts Amended Objs to Ptfs Depo Desgs.pdf

Follow Up Flag: Follow up Flag Status: Flagged

Maya,

See attached, in an abundance of caution, 1 just doubled check the docket and there appears to a late submission by Defendant [DE 826] which doesn't appear to be on the binder index. Attached is what I found in the unredacted e-mail distribution for this date.

I believe you should now have everything you need. Please do not hesitate to contact me should you need anything further. Sandra

From: Maya_H_Nuland@nysd.uscourts.gov [mailto:Maya_H_Nuland@nysd.uscourts.gov] Sent: Thursday, April 27, 2017 3:56 PM To: Sandra Perkins Cc: SweetNYSDChambers@nysd.uscourts.gov Subject: RE: v. Maxwell, Case No: 15-cv-07433-RWS

That is very helpful, thank you. I just want to make sure that there is nothing MISSING from the Binder that the Judge needs to rule on.

Maya Nuland Law Clerk to the Honorable Robert W. Sweet United States District Court for the Southern District of New York 500 Pearl Street, Suite 1940 New York, NY 10007-1312 (212) 805-0463

From: Sandra Perkins <inerkaraFORSFLLID coop To: *SweetNYS0Chambersanvsd.uscourta.00v- <SweetNYSDChamberailtnvsd.uscourts.00v> Cc: H NulandOwsd.uscourts we' <Maya H Nulandenna uscourta aoy> Dale: 04/27/2017 03:51 PM Subject: RE: v. Maxwell, Case No: 15-cv.07433•RWS

Maya, I hope this answers your question. There should be 10 items in the binder (which are both Plaintiff and Defendant submissions). However, the attached word versions relate to Plaintiff's submissions and should correspond to the binder tabs 1, 3, 6, 7, 9 and 10.

Please let me know if the binder has less than 10 items in it (or if there is anything missing) as it was assembled for us

Thank you and I apologize for any confusion, Sandra

01-13-2017 Plaintiff's Deposition Designations 1 01-27-2017 Plaintiffs Objections AND Cross Desi ations 3 02-06-2017 Plaintiffs Supplemental Designations ( 6 02-17-2017 Plaintiffs Objections to Defendant's Counter Designations............................................ 7 03-28-2017 Response to Defendant's Objections to Plaintiffs Designations 9 03-28-2017 Notice of filing Typographical Errors 10

From: Maya H NulandOnvsd.uscourts.00v [mailto:Mava H NulandOnvsd.uscourts.00vi On Behalf Of SweetNYSDChambers@nysd.uscourts.00v Sent: Thursday, April 27, 2017 3:40 PM To: Sandra Perkins Cc: SweetNYSDChambersOnvsd.uscourts.00v Subject: Re: v. Maxwell, Case No: 15-cv-07433-RWS

Thank you, Sandra. So which of these documents are what was in the binder? Since we received the binders on April 5, I understood that to contain the final versions of all of the deposition designations and objections to designations, incorporating all amendments, etc.

Sandra Perkins <suerkinsdbBSFLLP.crim>

04/27/2017 01.37 - PM

To the honorable Judge Sweet,

To "SweelNYSOChambersanvsd.uscourts.00v" <SweelNYSDChambersanvsd uscourts.00v>

cc "Maya H Nulandanvsd.uscourts.00e <Maya H Nulandanvsd.uscourts.O0O.

Subject I= v. Maxwell. Case No: 15-cv-07433-RWS

As a follow up to Maya Nuland's phone call request today, please see the below list of what should in the designations binder submitted to the Court, along with the word versions of Plaintiff's submissions (highlighted below). For the Court's convenience, I have also included a word document for "Tab 2 - Defendant's Deposition Designations (charted by BSF)" which was charted by BSF due to Defendant's 1/13/17 submission being received in highlighted transcript form.

Please feel free to contact me should you have any questions or need any additional information.

DEPOSITION DESIGNATIONS, COUNTER DESIGNATIONS & OBJECTIONS

01-13-2017 Plaintiff's Deposition Designations1
01-13-2017 Defendant's Deposition Designations (Charted by BSF)...2
01-27-2017 Plaintiffs Objections AND Cross Designations3
01-27-2017 Defendant's Objections to Plaintiffs Deposition Designations4
02-03-2017 Defendant's Counter-Designations to Plaintiff's Deposition Designations5
02-06-2017 Plaintiff's Supplemental Designations (=i )6
02-17-2017 Plaintiffs Objections to Defendant's Counter Designations7
02-17-2017 Defendant's Objections to Plaintiffs Cross Designations8
03-28-2017 Response to Defendant's Objections to Plaintiffs Designations9
03-28-2017 Notice of filing Typographical Errors10

Kindest Regards,

Sandra Perkins Borger Paralegal

IBOIES SCHILLER FLEXNER LLPI

401 E. Las Ofas Blvd. Suite 1200 Fat Lauderdale, FL. 33301

(I) +1 954 377 4219

(m) +1 954 356 0011

soerkinsetbsIllo.com

www.bsfllo.com

The information contained in this electronic message is confidential information intended only for the use of the named recipients) and may contain information that. among other protections. is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. I

The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections. is the subject of attorney-client pnvilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination, distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1

Draft: efta02805304

Other records

Prepared source

Exhibit A From: Sandra Perkins Sent: Thursday, April 27, 2017 4:12 PM To: 'Maya H Nuland@nysd.uscourts.gov' Cc: 'SweetNYSDChambers@nysd.uscourts.gov' Subject: RE: v. Maxwell, Case No: 15-cv-07433-RWS Attachments: 2017.04.03 Defts Amended Objs to Ptfs Depo Desgs.pdf Follow Up Flag: Follow up Flag Status: Flagged Maya, See attached, in an abundance of caution, 1 just doubled check the docket and there appears to a late submission by Defendant [DE 826] which doesn't appear to be on the binder index. Attached is what I found in the unredacted e-mail distribution for this date. I believe you should…