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Case 1:15-cv-07433-LAP Document 1325-4 Filed 01/04/24 Page 2 of 6 Sigrid McCawley From: Sigrid McCawley Sent: Tuesday, May 17, 2016 3:53 PM To: Laura Menninger; Meredith Schultz; Jeff Pagliuca Ca: ‘brad@pathtojustice.com' (brad@pathtojustice.com); Paul Cassell (cassellp@law.utah.edu) Subject: RE: Notice of Subpoena Attachments: May-June 2016 Deposition Calendar.pdf Hello Laura — We are working on the calendar and | have it almost complete but | was awaiting confirmation on a date from Mr, Rizzo’s counsel so | didn’t want to send it out prematurely and that was delaying me. We were serving subpoenas on dates that we thought are grouped within the locations/date ranges we discussed during the meet and confer and since we have been having an extraordinarily difficult time serving witnesses who appear to be attempting to evade service we need to keep that process moving. We do intend to work with you on dates as we discussed. Attached is the proposed calendar with the caveat that dates may shift if witnesses make change requests but we are doing our best to group locations together where possible. Again — this is not final as | noted | believe you had some dates you were gone but were checking with Jeff to determine his availability. Finally, we are writing to confer whether you will stipulate that we may exceed the 10 deposition limit to complete discovery in this case or whether we need to file a motion with the Court on that issue. Thank you, Sigrid Sigrid S. McCawley Partner BOIES, SCHELLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: 954-356-0011 ext. 4223 Fax: 954-356-0022 http://www.bsfllp.com From: Laura Menninger [mailto:Imenninger@hmflaw.com] Sent: Tuesday, May 17, 2016 3:19 PM To: Meredith Schultz; Jeff Pagliuca Cc: Sigrid McCawley; 'brad@pathtojustice.com' (brad@pathtojustice.com); Paul Cassell (cassellp@law.utah.edu) Subject: Re: Notice of Subpoena Sigrid and Brad - We had a conferral last week in which you promised to provide for conferral purposes a proposed schedule for depositions we both had requested in various locations. Rather than provide any such schedule, you have instead sent us notices for approximately 7 depositions in NY and Florida, one for an individual who you did not mention deposing and who does not appear among the extensive list of witnesses in your Rule 26 disclosures.