…all emails—whether saved or deleted – and irrespective of which account they came from; not a single responsive email was located - from any Mindspring account and no emails were located from Earthlink or any other secret, hidden, “undisclosed” email account…
…to relevant discovery. 7 Case 1:15-cv-07433-LAP Document 230 Filed 06/20/16 Page 11 of 19 It is completely unknown what other relevant and probative information will be uncovered in Plaintiff’s previously hidden accounts…
…could lead to the adjudication of this case. Due to all the redactions in the record, even the reasons for the Protective Order are hidden from the public. (ECF No. 39-1). Movant recognizes that this Court entered an order…