…they are disclosed for the first time now. The Court’s Order also appears to be based on certain misunderstandings of fact that Doe 171’s undersigned counsel are currently investigating. In short, Doe 171 does not intend to impose…
…d) of the Protocol. Here, the ambiguity in the September 25 Email may be the product of Does 1 and 2 misunderstanding the process provided by the Protocol, which to those unrepresented by counsel may understandably appear dense and convoluted. …
…do not exist; a misreading of Ms. Maxwell’s response; or a misunderstanding of the facts or law. The Court should deny the Motion to Compel. ARGUMENT I. The objections and responses to the RFPs are proper. A. RFP No…
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