…has already asserted objections on her own behalf to many of the documents that will be at issue. In any event, Plaintiff is willing to confer with Maxwell in good faith to address ways to alleviate her burden. For example…
…July 13, 2016 8:22 PM To: Jeff Pagliuca Subject: Fwd: Your motions Jeff, Look I'm not going to be dragged into these nonsense emails. I'm willing to help clear up miscommunication if that indeed occurred. However, I…
…As indicated in her March 14 correspondence, Ms. Maxwell’s counsel is willing to discuss her ESI discovery protocols, but only if such discussion begins at a rational starting point for a single-plaintiff, single-defendant case such as this…
…flat refusal to discuss her ESI protocols (“ [w]e do not believe we have an obligation to describe for your [sic] our document search methods”), Defendant now acknowledges in her Response brief some willingness to do so.3 Yet, still…