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Monday, December 07, 2015 1:50:04 PM
"Two of the documents Defendant produced only after it became apparent that Plaintiffs were about to file this motion to compel are particularly noteworthy. First, Defendant produced a memo
Ex. 12 at A081, UST00556835.
That fact utterly discredits Defendant’s “death spiral” explanation for why it imposed the Net Worth Sweep, and it is revealed in a memo that is clearly responsive to document requests that Plaintiffs propounded in April 2014. Even though it is clearly not privileged, Defendant did not produce this highly damaging document until last week. Also in
anticipation of this motion to compel, Defendant belatedly produced
Here again, it was only when threatened with a motion to compel 19 months after first receiving Plaintiffs’ document
8
Case 1:13-cv-00465-MMS Document 272 Filed 12/07/15 Page 16 of 46
requests that Defendant produced a clearly responsive document that it now concedes is not privileged and that directly undermines the basic narrative it has used to defend the Net Worth Sweep."
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