From: To: Subject: RE: Phone Call Follow-Up Date: Fri, 30 Oct 2020 18:54:08 +0000 Inline-Images: image001.png Thanks,MI We appreciate the help. I know this has been a big headache and created a lot of problems not just for us but for a number of other units, and we really appreciate you trying to get us across the finish line. From Sent: Friday, October 30, 2020 2:42 PM To: Subject: RE: Phone Call Follow-Up Understood From: Sent: Friday, October 30, 2020 2:41 PM To: Subject: RE: Phone Call Follow-Up Thanks,MI The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I realize that this is a big project and that there's only so much that can be done, but it poses almost insurmountable timing hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this one included, that eats up a huge chunk of the time we have available to produce discovery. We'll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline. From Sent: Friday, October 30, 2020 12:51 PM To: Subject: FW: Phone Call Follow-Up Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is still being imaged. Then it gets marked. Then copied to us. I have spoken to He thinks it is not possible to meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion might be possible. From: Koontz, Nicholas [US] Sent: Friday, October 30, 2020 12:25 PM To: Cc: Subject: Phone Call Follow-Up Good AfternoonE: Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via FedEx with the following productions in the