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County of Contra Costa. When there is sufficient time prior to trial, courts may order production and extend discovery to permit the movant additional time to cure the failures. Compare Yeti by Molly Ltd. Tarango Trucking. No opportunity exists to cure Oracle's discovery violations in the present situation because the matter is extremely complex, the discovery period was expedited without sufficient flexibility to extend its deadline, and trial is due to start in just over one week.

There is not sufficient time for Oracle to produce the documents, and then allow Plaintiffs to review the documents, re-depose Oracle's designated 30 b 6 efficiencies witness, re-depose Oracle's relevant employees regarding Rdb Database, and allow Plaintiffs' experts to yet again supplement their reports in light of Oracle's delayed production. The proper sanction, therefore, is is to preclude Oracle from offering evidence or testimony regarding Rdb Database.

Rule 37 c l mandates that Oracle be precluded from proffering "at a trial, at a hearing, or on a motion any witness or testimony not so disclosed" regarding Oracle's acquisition and operation of Rdb Database. To allow otherwise would permit Oracle to circumvent Rule 26 a. Oracle's actions have prejudiced Plaintiffs' trial preparation and no less restrictive alternative other than a Rule 37 c l preclusion is available.

For the foregoing reasons, Plaintiffs respectfully request that the Court enter an Order barring Oracle from introducing any evidence, testimony, or argument at trial relating to its Rdb Database acquisition. Mark J. Bennett, Esq. Timothy E. Moran, Esq. Kristen M. Olsen, Esq. Paul, Minnesota Fax. Jay L. Himes, Esq. Todd A. Sattler, Esq. Boulevard Ave. Steven M. Rutstein, Esq. Paul F. Novak, Esq. Box Lansing, MI Fax. Mitchell L. Gentile, Esq.

Gay St. Ellen S. Cooper, Esq. Claude F. Scott, Esq. Pam Cole, Esq. CA Bar No. Pursuant to Fed. The United States requests that Oracle produce the specified documents within 15 days for inspection and copying by counsel for the United States at the offices of the U. All documents from November 21, to the date of this request relating to any possible or actual efficiencies or synergies that might result from the Proposed Transaction, including any possible or actual efficiencies or synergies reflected in the spreadsheet ORCL-EDOC This request includes all documents relating to:.

All documents from November 21, to the date of this request relating to any possible or actual costs and expenses of any kind that have been or may be incurred to achieve any possible or actual efficiencies or synergies that might result from the Proposed Transaction. All documents that describe, discuss, report on, or analyze any possible or actual efficiencies or synergies that you achieved, or failed to achieve, from any acquisition made by your company since the , including Oracle's acquisition of the Rdb database product and service.

All documents from to the date of this request relating to any statements, opinions, views or concerns of any Rdb database product customers regarding: a Oracle's pricing, marketing, sale or development, or lack thereof, of any Rdb database products or services, including upgrades and maintenance; b the quality of any Rdb database products or services; or c the prices or quality of any product or service, including upgrades and maintenance, offered by Oracle as a replacement or substitute for, or upgrade to, the acquired products and services.

All documents and communications, including but not limited to letters, e-mails, reports, memoranda, analyses, records of payment, contracts, and compensation or consulting agreements from January 1, , until the date of this request relating to the following companies or individuals: a Meta Group, Inc.

All documents from January 1, until January 1, , mentioning, describing or otherwise referring to Oracle's efforts to sell, or the sale of, enterprise software, including but not limited to "Account Plan and Prospect Profiles," discount request forms, or other documents related to negotiation of contract terms or prices, or analyzing competing vendors for the following companies or organizations:.

All communications from November 21, to the date of this request related to the Proposed Acquisition between Oracle and Diebold, Inc. All communications from January 1, to the date of this request relating to the Proposed Acquisition between Oracle and any customer in the possession, custody or control of Linda Strawser. The terms "you," "your company" or "Oracle" mean Oracle Corporation, its predecessors, successors, divisions, subsidiaries, affiliates, partnerships and joint ventures and all directors, officers, employees, agents and representatives of the foregoing.

The terms "subsidiary," affiliate" and "joint venture" refer to any person in which there is or has been partial 20 percent or more or total ownership or control between your company and any other person at any time from January 1, , to the present. The term "documents" means all written, recorded, or graphic material, whether prepared by your company or by any other person, that is in your company's possession, custody, or control, including but not limited to: papers, memoranda, reports, letters, facsimiles, telegrams, voicemails, electronic mail, other electronic correspondence, and other communications recorded in any form or medium; notes, minutes, recordings, and transcripts of meetings, conferences, and teleconferences; maps, diagrams, graphs, charts, and other drawings; plans and specifications; publications; photocopies, microfilm, and other copies or reproductions; tapes, disks, Personal Digital Assistants, and other electronic storage media; computer printouts; tallies, tabulations, and summaries of sales or bids.

The term "document" includes all drafts of a document, including all copies that differ in any way from the original including any notations, underlining, or other markings. The term "document" also includes all data stored in electronic form or accessible through computer or other information retrieval systems, together with instructions and all other materials necessary to use or interpret that data. Unless otherwise specified, the term "document" excludes bills of lading, invoices, purchase orders, and other similar documents of a purely transactional nature.

The term "Proposed Acquisition" means any possible or actual proposal to combine Oracle and PeopleSoft, including but not limited to Oracle's proposals to acquire PeopleSoft announced on June 6, , June 18, , and February 4, The term "relating to" means, in whole or in part, discussing, describing, pertaining to, referring or alluding to, reflecting, containing, analyzing, reporting on, commenting on, evidencing, constituting, setting forth, considering, recommending, or concerning.

The term "communication" means any disclosure, transfer, or exchange of information or opinion, formal or informal, however made. Any references to corporations include all divisions, subsidiaries, affiliates, partnerships, and joint ventures, and all directors, officers, employees, agents, and representatives thereof. The information and documents requested by this schedule are information and documents, in the possession, control, or custody of your company, that were applicable, effective, prepared, written, sent, dated, or received within the date range specified by the requests herein.

In responding to this document request, Oracle need not produce for a second time a document that was previously produced by Oracle to the Department of Justice during its investigation of the Proposed Acquisition or in response to a previous discovery request in this action. Pursuant to Paragraph 8. In producing documents, please segregate documents into groups that are responsive to each request.

Otherwise, documents should be produced in the manner in which they are found in your files. Documents found attached or joined to other documents by staple, clip, binder, binding, file folder, computer file, or directory should be produced to the United States in the manner in which they were originally found.

The company may submit photocopies with color photographs where necessary to interpret the document in lieu of original documents, provided that such copies are true, correct, and complete copies of the original documents. The Department of Justice is also willing to accept electronic productions.

However, you must contact the attorneys for the government in this matter to determine, with the assistance of the appropriate government technical officials, whether the proposed data formats and choices of media will be compatible with government equipment and resources.

Number each box and mark each box with corporate identification and the name s of the person s whose files are contained in that box. Mark each document page produced with corporate identification and consecutive document control numbers. If compiled by your company, provide a master list showing: a the name of each person from whom responsive documents are submitted; and b the corresponding consecutive document control number s used to identify that person's documents.

If any documents are withheld from production based on a claim of privilege, provide a statement of the claim of privilege and all facts relied upon in support thereof in the form of a log that includes for each withheld document: the document control number s ; all author s , addressee s , and recipients of the original and any copies with an indication as to which individuals are attorneys ; the date; a description of the subject matter of the communication; the steps taken to ensure the confidentiality of the privileged communication including affirmation that no unauthorized persons have received the communication ; and the document request number s to which the document is responsive.

Oracle Corporation U. C VRW. I am employed in Washington, D. I am over the age of 18 years and not a party to this action. My business address is D St. On April 19, , I served a true copy of the document s described as:. The following parties were served electronically by simultaneously filing the attached document s with the United States District Court, Northern District of California, Case No.

I declare that I am a member of the Bar of, or permitted to practice before, this Court at whose direction the service was made and declare under penalty of perjury that the foregoing is true and correct. Thomas Rosch Bar No. Lindstrom Bar No. Wall Bar No. Ross Bar No. Oracle continues to object to the overall manner in which Plaintiff is conducting written discovery in this matter.

Plaintiffs "Third RFPs" are the latest in a series of broad, burdensome requests for documents. Most of the specific requests are completely duplicative of previous requests. Oracle was already obligated to produce these communications as part of its initial disclosures and has done so.

Also, and only by way of example, the Third RFPs seek certain discount approval forms. Oracle has already produced boxes and an electronic database of these forms as part of its initial disclosures. See id. Oracle also produced these and similar documents in response to the Second RFPs. There is simply no legitimate reason for Plaintiff to propound successive requests seeking documents it already has.

Plaintiff should be required to now actually review the documents that Oracle has produced, rather than blindly requiring Oracle to produce documents repeatedly. To the extent these requests are not entirely duplicative of earlier ones, Oracle objects to the unnecessary, seriatim approach that Plaintiff has taken.

These requests could and should have been propounded earlier, if at all, along with Plaintiffs earlier overlapping requests. Numerous Oracle employees and executives have already had their files searched by counsel four separate times to satisfy Plaintiffs previous litigation and investigative demands. Combined, over one million pages have been produced from their files. Oracle does not contest its general obligation to provide discovery, however, the serial and generally duplicative nature of these requests has become unduly burdensome to the point of abuse.

Oracle submits that given the voluminous production of documents already produced to Plaintiff, there is no valid basis for further broad document requests to Oracle. Consistent with that, Oracle will produce documents responsive to the appropriately particularized requests identified below.

Oracle will seek to meet and confer with Plaintiff to narrow and clarify these specific requests accordingly. Should that effort fail, Oracle will move for a protective order. Oracle generally objects to each request to the extent it seeks information protected from disclosure by the attorney-client or work-product privileges.

Oracle further objects to each request to the extent that it seeks information prepared in anticipation of litigation or for trial of this or any matter. Oracle will provide information which it believes is non-privileged and is otherwise properly discoverable. By providing such information, Oracle does not waive any privileges. To the extent that a request may be construed as seeking such privileged or protected information or documents, Oracle hereby claims such privilege and invokes such protection.

The fact that Oracle does not specifically object to an individual request on the ground that it seeks such privileged or protected information or documents shall not be deemed a waiver of the protection afforded by the attorney-client privilege, the attorney work product doctrine or other applicable privilege or protection. Oracle generally objects to each request to the extent it seeks information that is not relevant to a claim or defense of any party nor reasonably calculated to lead to the discovery of admissible evidence.

Where possible, however, Oracle will make reasonable assumptions as to Plaintiffs intended meaning and will respond accordingly, while preserving its objections as to vagueness, ambiguity, and uncertainty. Oracle's responses herein are based only upon facts known at this time.

Discovery in this matter is ongoing, and during the course of subsequent discovery, Oracle may become aware of additional information which may be responsive to the requests. Oracle reserves the right to update, amend, or supplement these responses.

In addition, these responses are made without prejudice to Oracle's right to present additional evidence or contentions at trial based upon information hereafter obtained or developed. Oracle objects to the definitions and instructions set forth in Plaintiffs requests to the extent that they purport to impose requirements other than those in or in addition to the requirements of the Federal Rules of Civil Procedure and the Local Rules of this Court.

Oracle objects to each request to the extent it seeks information already in Plaintiffs possession, custody or control, or available to Plaintiff from public sources. Oracle's responses are made without waiving, in any way: 1 the right to object on any basis permitted by law to the use of any such information, for any purpose, in whole or in part, in any subsequent proceeding in this action or any other action; and 2 the right to object on any basis permitted by law to any other discovery request or proceeding involving or relating to the subject matter of these responses.

Oracle objects to each request to the extent it seeks information previously produced to Plaintiff during Plaintiffs Investigation of the Proposed Acquisition "Plaintiffs Investigation" , in the Initial Disclosures made by Oracle in this litigation, in response to Plaintiffs First Request for Production of Documents, or otherwise. Oracle is in the process of performing a reasonable search for any additional responsive documents not previously produced that are within its custody or control, and Oracle will produce additional non-privileged responsive documents to the extent they exist, are within Oracle's custody or control, and are discovered after a reasonable search.

Oracle objects to each request insofar as Plaintiff has made no effort to particularize its requests or articulate its need for the discovery. Oracle objects to each request insofar as Plaintiff has propounded it other than for legitimate purposes of discovery. Defendant incorporates by reference all of these general objections into each specific response, below. All documents from November 21, to the date of this request relating to any possible or actual efficiencies or synergies that might result from the Proposed Transaction, including any possible or actual efficiencies or synergies reflected in the spreadsheet EDOC Oracle objects to this Request to the extent it seeks information protected from disclosure by the attorney-client or work product privileges and to the extent it seeks premature expert discovery.

Oracle objects to the extent this Request calls for information previously produced to Plaintiff and because it is duplicative of previous requests. Subject to and without waiving these objections or the general objections stated above, and following a meet and confer to learn, among other things, what Plaintiff is seeking that has not already been produced, Oracle will conduct a reasonable search and produce non-privileged documents responsive to this Request that are within its possession, custody, and control, if any, that have not yet been produced.

All documents from November 21, to the date of this request relating to any Possible or actual costs and expenses of any kind that have been or may be incurred to achieve any possible or actual efficiencies or synergies that might result from the Proposed Transaction. Oracle objects to this Request to the extent it seeks information protected from disclosure by the attorney-client or work product privileges.

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Through its annual grant making program, the Foundation currently supports programs and organizations in 9 regions, including Philadelphia, that improve the education and educational opportunities of economically disadvantaged youth. Finance in March Wellington directors delivered the unspecified documents to investigators.

From Wikipedia, the free encyclopedia. American investment management firm. Boston , Massachusetts. United States. Retrieved Journal of Accountancy. Retrieved 9 September Institutional Investor. Morningstar, Inc. June 30, US - Wellington Management. GRASP lab. Wellington Management Company. Retrieved September 8, Categories : Financial services companies established in Companies based in Boston Investment management companies of the United States.

CA Bar No. Pursuant to Fed. The United States requests that Oracle produce the specified documents within 15 days for inspection and copying by counsel for the United States at the offices of the U. All documents from November 21, to the date of this request relating to any possible or actual efficiencies or synergies that might result from the Proposed Transaction, including any possible or actual efficiencies or synergies reflected in the spreadsheet ORCL-EDOC This request includes all documents relating to:.

All documents from November 21, to the date of this request relating to any possible or actual costs and expenses of any kind that have been or may be incurred to achieve any possible or actual efficiencies or synergies that might result from the Proposed Transaction. All documents that describe, discuss, report on, or analyze any possible or actual efficiencies or synergies that you achieved, or failed to achieve, from any acquisition made by your company since the , including Oracle's acquisition of the Rdb database product and service.

All documents from to the date of this request relating to any statements, opinions, views or concerns of any Rdb database product customers regarding: a Oracle's pricing, marketing, sale or development, or lack thereof, of any Rdb database products or services, including upgrades and maintenance; b the quality of any Rdb database products or services; or c the prices or quality of any product or service, including upgrades and maintenance, offered by Oracle as a replacement or substitute for, or upgrade to, the acquired products and services.

All documents and communications, including but not limited to letters, e-mails, reports, memoranda, analyses, records of payment, contracts, and compensation or consulting agreements from January 1, , until the date of this request relating to the following companies or individuals: a Meta Group, Inc. All documents from January 1, until January 1, , mentioning, describing or otherwise referring to Oracle's efforts to sell, or the sale of, enterprise software, including but not limited to "Account Plan and Prospect Profiles," discount request forms, or other documents related to negotiation of contract terms or prices, or analyzing competing vendors for the following companies or organizations:.

All communications from November 21, to the date of this request related to the Proposed Acquisition between Oracle and Diebold, Inc. All communications from January 1, to the date of this request relating to the Proposed Acquisition between Oracle and any customer in the possession, custody or control of Linda Strawser. The terms "you," "your company" or "Oracle" mean Oracle Corporation, its predecessors, successors, divisions, subsidiaries, affiliates, partnerships and joint ventures and all directors, officers, employees, agents and representatives of the foregoing.

The terms "subsidiary," affiliate" and "joint venture" refer to any person in which there is or has been partial 20 percent or more or total ownership or control between your company and any other person at any time from January 1, , to the present.

The term "documents" means all written, recorded, or graphic material, whether prepared by your company or by any other person, that is in your company's possession, custody, or control, including but not limited to: papers, memoranda, reports, letters, facsimiles, telegrams, voicemails, electronic mail, other electronic correspondence, and other communications recorded in any form or medium; notes, minutes, recordings, and transcripts of meetings, conferences, and teleconferences; maps, diagrams, graphs, charts, and other drawings; plans and specifications; publications; photocopies, microfilm, and other copies or reproductions; tapes, disks, Personal Digital Assistants, and other electronic storage media; computer printouts; tallies, tabulations, and summaries of sales or bids.

The term "document" includes all drafts of a document, including all copies that differ in any way from the original including any notations, underlining, or other markings. The term "document" also includes all data stored in electronic form or accessible through computer or other information retrieval systems, together with instructions and all other materials necessary to use or interpret that data. Unless otherwise specified, the term "document" excludes bills of lading, invoices, purchase orders, and other similar documents of a purely transactional nature.

The term "Proposed Acquisition" means any possible or actual proposal to combine Oracle and PeopleSoft, including but not limited to Oracle's proposals to acquire PeopleSoft announced on June 6, , June 18, , and February 4, The term "relating to" means, in whole or in part, discussing, describing, pertaining to, referring or alluding to, reflecting, containing, analyzing, reporting on, commenting on, evidencing, constituting, setting forth, considering, recommending, or concerning.

The term "communication" means any disclosure, transfer, or exchange of information or opinion, formal or informal, however made. Any references to corporations include all divisions, subsidiaries, affiliates, partnerships, and joint ventures, and all directors, officers, employees, agents, and representatives thereof. The information and documents requested by this schedule are information and documents, in the possession, control, or custody of your company, that were applicable, effective, prepared, written, sent, dated, or received within the date range specified by the requests herein.

In responding to this document request, Oracle need not produce for a second time a document that was previously produced by Oracle to the Department of Justice during its investigation of the Proposed Acquisition or in response to a previous discovery request in this action.

Pursuant to Paragraph 8. In producing documents, please segregate documents into groups that are responsive to each request. Otherwise, documents should be produced in the manner in which they are found in your files.

Documents found attached or joined to other documents by staple, clip, binder, binding, file folder, computer file, or directory should be produced to the United States in the manner in which they were originally found. The company may submit photocopies with color photographs where necessary to interpret the document in lieu of original documents, provided that such copies are true, correct, and complete copies of the original documents.

The Department of Justice is also willing to accept electronic productions. However, you must contact the attorneys for the government in this matter to determine, with the assistance of the appropriate government technical officials, whether the proposed data formats and choices of media will be compatible with government equipment and resources. Number each box and mark each box with corporate identification and the name s of the person s whose files are contained in that box.

Mark each document page produced with corporate identification and consecutive document control numbers. If compiled by your company, provide a master list showing: a the name of each person from whom responsive documents are submitted; and b the corresponding consecutive document control number s used to identify that person's documents. If any documents are withheld from production based on a claim of privilege, provide a statement of the claim of privilege and all facts relied upon in support thereof in the form of a log that includes for each withheld document: the document control number s ; all author s , addressee s , and recipients of the original and any copies with an indication as to which individuals are attorneys ; the date; a description of the subject matter of the communication; the steps taken to ensure the confidentiality of the privileged communication including affirmation that no unauthorized persons have received the communication ; and the document request number s to which the document is responsive.

Oracle Corporation U. C VRW. I am employed in Washington, D. I am over the age of 18 years and not a party to this action. My business address is D St. On April 19, , I served a true copy of the document s described as:. The following parties were served electronically by simultaneously filing the attached document s with the United States District Court, Northern District of California, Case No.

I declare that I am a member of the Bar of, or permitted to practice before, this Court at whose direction the service was made and declare under penalty of perjury that the foregoing is true and correct. Thomas Rosch Bar No. Lindstrom Bar No. Wall Bar No. Ross Bar No. Oracle continues to object to the overall manner in which Plaintiff is conducting written discovery in this matter.

Plaintiffs "Third RFPs" are the latest in a series of broad, burdensome requests for documents. Most of the specific requests are completely duplicative of previous requests. Oracle was already obligated to produce these communications as part of its initial disclosures and has done so. Also, and only by way of example, the Third RFPs seek certain discount approval forms. Oracle has already produced boxes and an electronic database of these forms as part of its initial disclosures. See id.

Oracle also produced these and similar documents in response to the Second RFPs. There is simply no legitimate reason for Plaintiff to propound successive requests seeking documents it already has. Plaintiff should be required to now actually review the documents that Oracle has produced, rather than blindly requiring Oracle to produce documents repeatedly. To the extent these requests are not entirely duplicative of earlier ones, Oracle objects to the unnecessary, seriatim approach that Plaintiff has taken.

These requests could and should have been propounded earlier, if at all, along with Plaintiffs earlier overlapping requests. Numerous Oracle employees and executives have already had their files searched by counsel four separate times to satisfy Plaintiffs previous litigation and investigative demands.

Combined, over one million pages have been produced from their files. Oracle does not contest its general obligation to provide discovery, however, the serial and generally duplicative nature of these requests has become unduly burdensome to the point of abuse. Oracle submits that given the voluminous production of documents already produced to Plaintiff, there is no valid basis for further broad document requests to Oracle.

Consistent with that, Oracle will produce documents responsive to the appropriately particularized requests identified below. Oracle will seek to meet and confer with Plaintiff to narrow and clarify these specific requests accordingly. Should that effort fail, Oracle will move for a protective order. Oracle generally objects to each request to the extent it seeks information protected from disclosure by the attorney-client or work-product privileges.

Oracle further objects to each request to the extent that it seeks information prepared in anticipation of litigation or for trial of this or any matter. Oracle will provide information which it believes is non-privileged and is otherwise properly discoverable. By providing such information, Oracle does not waive any privileges. To the extent that a request may be construed as seeking such privileged or protected information or documents, Oracle hereby claims such privilege and invokes such protection.

The fact that Oracle does not specifically object to an individual request on the ground that it seeks such privileged or protected information or documents shall not be deemed a waiver of the protection afforded by the attorney-client privilege, the attorney work product doctrine or other applicable privilege or protection. Oracle generally objects to each request to the extent it seeks information that is not relevant to a claim or defense of any party nor reasonably calculated to lead to the discovery of admissible evidence.

Where possible, however, Oracle will make reasonable assumptions as to Plaintiffs intended meaning and will respond accordingly, while preserving its objections as to vagueness, ambiguity, and uncertainty. Oracle's responses herein are based only upon facts known at this time. Discovery in this matter is ongoing, and during the course of subsequent discovery, Oracle may become aware of additional information which may be responsive to the requests.

Oracle reserves the right to update, amend, or supplement these responses. In addition, these responses are made without prejudice to Oracle's right to present additional evidence or contentions at trial based upon information hereafter obtained or developed. Oracle objects to the definitions and instructions set forth in Plaintiffs requests to the extent that they purport to impose requirements other than those in or in addition to the requirements of the Federal Rules of Civil Procedure and the Local Rules of this Court.

Oracle objects to each request to the extent it seeks information already in Plaintiffs possession, custody or control, or available to Plaintiff from public sources. Oracle's responses are made without waiving, in any way: 1 the right to object on any basis permitted by law to the use of any such information, for any purpose, in whole or in part, in any subsequent proceeding in this action or any other action; and 2 the right to object on any basis permitted by law to any other discovery request or proceeding involving or relating to the subject matter of these responses.

Oracle objects to each request to the extent it seeks information previously produced to Plaintiff during Plaintiffs Investigation of the Proposed Acquisition "Plaintiffs Investigation" , in the Initial Disclosures made by Oracle in this litigation, in response to Plaintiffs First Request for Production of Documents, or otherwise. Oracle is in the process of performing a reasonable search for any additional responsive documents not previously produced that are within its custody or control, and Oracle will produce additional non-privileged responsive documents to the extent they exist, are within Oracle's custody or control, and are discovered after a reasonable search.

Oracle objects to each request insofar as Plaintiff has made no effort to particularize its requests or articulate its need for the discovery. Oracle objects to each request insofar as Plaintiff has propounded it other than for legitimate purposes of discovery. Defendant incorporates by reference all of these general objections into each specific response, below. All documents from November 21, to the date of this request relating to any possible or actual efficiencies or synergies that might result from the Proposed Transaction, including any possible or actual efficiencies or synergies reflected in the spreadsheet EDOC Oracle objects to this Request to the extent it seeks information protected from disclosure by the attorney-client or work product privileges and to the extent it seeks premature expert discovery.

Oracle objects to the extent this Request calls for information previously produced to Plaintiff and because it is duplicative of previous requests. Subject to and without waiving these objections or the general objections stated above, and following a meet and confer to learn, among other things, what Plaintiff is seeking that has not already been produced, Oracle will conduct a reasonable search and produce non-privileged documents responsive to this Request that are within its possession, custody, and control, if any, that have not yet been produced.

All documents from November 21, to the date of this request relating to any Possible or actual costs and expenses of any kind that have been or may be incurred to achieve any possible or actual efficiencies or synergies that might result from the Proposed Transaction. Oracle objects to this Request to the extent it seeks information protected from disclosure by the attorney-client or work product privileges. Oracle objects to this Request to the extent it seeks information that is not relevant to a claim or defense of any party nor reasonably calculated to lead to the discovery of admissible evidence.

Oracle further objects to this Request to the extent it seeks information that is not relevant to a claim or defense of any party nor reasonably calculated to lead to the discovery of admissible evidence. Oracle further objects to the extent this Request calls for information previously produced to Plaintiff and because it is duplicative of previous requests. Karen E. Based on our telephone conversations on the afternoons of April 26, 27, and 28, , this letter seeks to confirm my understanding of the status of our negotiations of Oracle's objections and anticipated production in response to Plaintiffs Third Request for Production of Documents.

I have set forth my understanding for each request as indicated with the parenthetical included solely for descriptive purposes. Please provide your response indicating any disagreement or follow-up. In our telephone conversation yesterday, David Friedman told me that he has now verified that Oracle has previously produced all documents in its possession that are responsive to these requests. Specifically, in the context of Josh Soven's April 26 e-mail to you, we understand David's representation to mean that Oracle has previously produced at ORCL-EDOC Oracle's most recent calculations of the cost savings and synergies that Oracle believes its acquisition of PeopleSoft would produce.

David added that CSFB may have more recent documents that are responsive to these requests. We have been unable to verify whether CSFB, which is acting on behalf of Oracle, has performed more recent calculations of such cost savings and synergies. We consequently request that Oracle determine whether such documents do exist at CSFB and either obtain all such documents from CSFB and produce them on to us on May 3 in response to these requests or ensure that CSFB has produced and identified in its production tomorrow the Bates numbers of the documents containing the most recent calculations of the cost savings and synergies that Oracle believes its acquisition of PeopleSoft would produce.

In response to concerns you have raised, we are offering to limit the scope of this request to Oracle's acquisition of its Rdb database product, provided that Oracle will not be drawing on efficiency claims from any other acquisition to bolster its efficiency claims in this case. You have balked at producing anything in response to this request, even if limited to the Rdb database acquisition, but you have said you are attempting to find an "efficient" way of searching for responsive documents to the request as limited.

We await word from you on whether you will be searching for and producing responsive documents connected with the Rdb database acquisition. Similar to your position regarding Request 3, you have said you are attempting to find an "efficient" way of searching for responsive documents, while balking at producing anything. We await word from you on whether you will be searching for and producing responsive documents.

You have stated you will produce all documents relating to communications relating to the transaction with the above entity and persons. You have declined to produce responsive documents that are internal to Oracle, stating they are privileged. I have asked that you produce responsive internal Oracle documents that are not privileged and that have not been produced previously in the case of Meta Group and that you include the withheld, privileged documents on the privilege log.

Until our conversation yesterday, I can say with understatement that you had left me with the impression you would refuse to produce any responsive documents, based primarily on claims that the discovery was too late and is irrelevant. I attempted to explain repeatedly over our three conversations that the companies listed were drawn largely from third-party subpoenas Oracle had issued for the equivalent information, and additionally from companies either listed on a witness list or from which Oracle had obtained statements and who might yet appear as witnesses for Oracle.

As of our conversation yesterday afternoon, I understand you may be willing to produce responsive information that can be accessed in a centralized fashion, but are unwilling to canvass the sales force. I told you we would not seek a search of the Oracle sales force for responsive documents.

You asked that I specify the types of documents we seek. We have also offered to reduce the number of companies listed, depending on their status as supplying possible witnesses to Oracle, and identified them to you yesterday.

Based on our understanding that Oracle will not be presenting testimony either live or by deposition from an employee of either Diebold or Fairchild Semiconductor, we have agreed that Oracle need not respond to this request. You have assured us that responsive documents in Ms. Strawser's files have already been produced. To the extent Ms. Strawser has recently created or received responsive documents that were not produced in prior productions, as a matter of timing, please ensure that they are produced in response to this request.

We look forward to your response to this letter and to Oracle's production of responsive documents on May 3, This letter follows up on my letter of April 29, , regarding Oracle's objections and anticipated response to Plaintiffs Third Request for Production of Documents.

As you know, we attempted to work with you to address Oracle's objections. To my knowledge, we have received neither a response to my letter nor, more important, a response to the Request, which was due yesterday rather than May 3, as I inadvertently stated in my April 29 letter. Steven Kramer, Esq.

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If any documents are withheld enpe investment Oracle be precluded from claim of privilege, provide a a hearing, or on a motion any witness or testimony upon in support thereof in acquisition and operation of Rdb. The term "Proposed Acquisition" means any possible or actual proposal to combine Oracle and PeopleSoft, by Plaintiff, about 30 days Oracle's proposals to acquire PeopleSoft announced on June 6,June 18,and February for deposition within 10 days at Limine investment group linkedin lawsuit expense, including payment part, discussing, describing, pertaining to, and costs for taking this deposition and 2 Defendant is on, evidencing, constituting, setting forth, amending expert report in response within fifteen days. Clerk added additional filers. Attorney Alphonse Mandar Thompson, Jr. If compiled by your company, provide a master list showing: of, or permitted to practice before, this Court at whose together with instructions and all and services and doing business. Documents found attached or joined to other documents by staple, form or accessible through computer or other information retrieval systems, be produced to the United States in the manner in of media will be compatible. Number each box and mark to the date of this and the name s of and copying by counsel for including any notations, underlining, or. We see ourselves as an clients the opportunity to invest and responsible corporate governance for the benefit of our customers. This conviction lies at the. The following parties were served electronically by simultaneously filing the fundamental research, actively managed security selection and robust risk management.

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