NorthWest Biotherapeutics Inc (NWBO)

[pqr]

PM the standard applicable to the scope of permissible discovery is any non-privileged information that is relevant to the claim OR that might lead to such information. Does not have to be admissible at trial. The same standard applies to party and non-party witnesses. “Relevant” means tends to make a fact at issue more or less likely. IMO it’s not an issue of “sources” but communications.

NWBO would seek to obtain communications from the defendants or others, not a journalist. However if NWBO felt Mr Feurstein was communicating to hide, advance, or certainly, plan ahead of time, a “fraud” (Count 3 claims fraud) or an illegal
act (spoofing is both civilly actionable and a crime), IMO NWBO would have a pretty good shot at recovering any of his or Stat communications they were unable to obtain elsewhere.

All kinds of issues to be addressed.