EXHIBIT 1¶
401 EAST LAS OLAS BOULEVARD • SUITEI200• FORT LAUDERDALE. FL 33301- 2211• PH 954.356.0011 • FAX 954 356.0022¶
Sigrid S. McCawley, Esq. E-mail: smccawley@bsfIlp.com¶
March 28, 2016¶
VIA E-MAIL¶
Laura A. Menninger, Esq. Jeffrey Paiolisq. lit I IADDON, AND 150 East 10 Avenue Dever, Colorado 80203 Imenninger(atmflaw.com P.C.¶
Re: Guiffre v. Maxwell Case No. 15-cv-07433-RWS
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Dear Ms. Menninger and Mr. Pagliuca,¶
Pursuant to the Court's Order in the above-styled case, we request that you produce documents as directed by the Court at the hearing on March 17, 2016. As you know, we originally served out discovery requests on October 27, 2015. Therefore, we believe a reasonable time period for production of the documents is twenty (20) days from the Court's ruling which would be by April 6, 2016. See March 17, 2016, Hearing Transcript at p. 30-33.¶
We also request that you provide the search terms, if any, you used for your search of electronically stored information, and we request that you describe your processes in collecting and preserving such information.¶
Please let me know if you have any questions.¶
SSM:ms Enclosures Sincerely,¶
7V -¶
Sigrid S. McCawley¶