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I was about to paste it but it's a link to goatse. If you don't know what that is, it's a dude gaping his ass super huge with his dick and balls hanging out. google it.
While I, like you, don’t relish being involved in discovery disputes, I think that may be unavoidable at this point because we quite simply have a very different recollection of what transpired at the hearing, and I don’t think that more email traffic is going to bring us any closer . What time tomorrow is good for you to discuss this in more detail?
Since we’re already engaged with respect to this particular issue, there are a couple of other matters that I think we need to discuss as well. As you know, Plaintiff moved to compel full and complete responses to Interrogatories 9-11 and Requests for Production 6-7. The Court granted Plaintiff’s motion, with the only limitation noted being with respect to the time frame.
Nevertheless, in providing your Third Supplemental Responses to Plaintiff’s Request for Production responding to RFP 7 (which was one of the requests at issue in the motion), Defendant has objected to the request, including new objections that were not made in original response thereto. With the Court having already ruled upon Plaintiff’s request and found it to be appropriate, the inclusion of these objections is obviously improper. With the propriety of Plaintiff’s request having already been ruled upon, and with you having had the opportunity to raise these objections when the request was propounded or with the Court during the telephonic hearing and chose not to do so, they have been waived.
This applies with equal force to your new assertion of privilege over certain materials. This assertion should have been made long, long ago when Defendant originally responded to Plaintiff’s request, and the failure to do so then constitutes a waiver. Even had the privilege not been waived, however, its assertion would still not be appropriate, as we are unaware of any 9th Circuit authority that recognizes a “governmental deliberation process/critical self-critical privilege.” If you can direct us to such authority, please let me know, but as of right now, I am operating under the impression that no such privilege is recognized in this Circuit.
Moreover, Federal Rule 26(b)(5)(ii) expressly provides that when privilege is asserted, the party asserting the privilege must, “describe the nature of the documents, communications, or tangible things not produced or disclosed — and do so in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.” The privilege log that has been provided falls short in this respect, particularly in light of the fact that neither the authors nor the recipients are identified. It is impossible for us to assess the basis for a claim of attorney-client privilege when no attorneys are identified on the privilege log.
Finally, all of the foregoing notwithstanding, we need to connect with respect to our obligation to discuss how to get individual files sampled by hand, per the Court’s order. We’d like to discuss that during our call as well.
Please let me know your availability as soon as possible.
MediaFire is a simple to use free service that lets you put all your photos, documents, music, and video in a single place so you can access them anywhere and share them everywhere.
MediaFire is a simple to use free service that lets you put all your photos, documents, music, and video in a single place so you can access them anywhere and share them everywhere.
01-Jock Scot with The Nectarine No9 “Thierry Lacroix”
02-Plastikman “09:21″
03-Matt Nordstrom “Lucky Drawls”
04-Edgar de Ramon “Gate 242″
05-Johnny D “Requiem of a Dream”
06-Soundexile “Disturbed (Franco Cinelli remix)”
07-Noze “You Have To Dance (Mathias Kaden Beatpolka remix)”
08-Maskio “Human Jungle (Santos re edit)”
09-Reebot “Vandon”
10-Deadmau5 “Sometimes Thing Get Whatever”
11-Behrouz, Andy Chatterley “Lost In Transition (Timo Maas Mad Day Remix)”
12-Plastikman “06:11″
13-Kolombo “Acai (Delon&Dalcan remix)”
14-Paolo Mojo, Jim Rivers “Ron Hardy Said (Eric Prydz remix)”
15-Emmanuel Top “Generation”
16-Ben Klock “Before”
17-Cirez D “Läget”
18-Astronivo “Anything You Want feat.DJ Zombi (Miki Litvak & Ido Ophir remix)”
19-Alex Dolby “Psiko Garden”
20-bRUNA “From Lovers To Friends”
__________________
Originally posted by TheVrk
it IS incredible isn't it??
STILL pumpin out great set after great set...never cheesed out, never sold out, never lost his touch..
Simply does not get any better than Hernan
MediaFire is a simple to use free service that lets you put all your photos, documents, music, and video in a single place so you can access them anywhere and share them everywhere.
MediaFire is a simple to use free service that lets you put all your photos, documents, music, and video in a single place so you can access them anywhere and share them everywhere.
01-Jock Scot with The Nectarine No9 “Thierry Lacroix”
02-Plastikman “09:21″
03-Matt Nordstrom “Lucky Drawls”
04-Edgar de Ramon “Gate 242″
05-Johnny D “Requiem of a Dream”
06-Soundexile “Disturbed (Franco Cinelli remix)”
07-Noze “You Have To Dance (Mathias Kaden Beatpolka remix)”
08-Maskio “Human Jungle (Santos re edit)”
09-Reebot “Vandon”
10-Deadmau5 “Sometimes Thing Get Whatever”
11-Behrouz, Andy Chatterley “Lost In Transition (Timo Maas Mad Day Remix)”
12-Plastikman “06:11″
13-Kolombo “Acai (Delon&Dalcan remix)”
14-Paolo Mojo, Jim Rivers “Ron Hardy Said (Eric Prydz remix)”
15-Emmanuel Top “Generation”
16-Ben Klock “Before”
17-Cirez D “Läget”
18-Astronivo “Anything You Want feat.DJ Zombi (Miki Litvak & Ido Ophir remix)”
19-Alex Dolby “Psiko Garden”
20-bRUNA “From Lovers To Friends”
__________________
Never heard this dj before, gonna check it out, thanks Didi
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