HomeMy WebLinkAboutExhibit A to Declaration of Tamara Crisp in Support of City of Renton's Opposition to Tracfone's Motion to Compel Audit FileFrom: Degginger, Grant <DeggingerG@LanePowell.com>
Sent: Wednesday, January 13, 2021 6:05 PM
To: TRS <crisp@trs-integrity.com>
Cc: Edwards, Scott M. <EdwardsS@LanePowell.com>; Kari L. Sand <ksand@omwlaw.com>
Subject: RE: Rescheduling the phone call
Tamara,
We were disappointed that you did not participate in the call that Kari Sand set up
yesterday. Please copy Scott and Kari on any response.
1. As discussed at your second deposition, you need to produce complete copies of
all correspondence to and from TracFone. Despite having the better part of a year to
accomplish this, you have not done so. The way to correct this deficiency and
preserve confidentiality of your other clients is to convert each email to an individual
PDF and redact only the names of other TRS clients (or other words that would
disclose the identity – as opposed to the existence of – any other TRS client).
It is not permissible to alter any words in the emails. Period. Making changes such as
altering the word “cities” to read “city” is not a “redaction” and is not permissible.
2. Schedules. You have produced in multiple batches of electronic copies of
schedules that have the same name but different content. For example you have
produced multiple files titled “ExcelPrelim3Renton Tracfone.xls” that assert different
amounts of interest due. After the second day of your deposition, you produced files
with the titles “ExcelPrelim3Renton TracFoneA.xls” and ExcelPrelim3Renton
TracFone (higher interest)AA.xls” which appear to have the same content, including
the same interest amount, as some of the prior produced files without any A or AA in
the document name. It is unclear when documents were renamed and how many
different versions of draft schedules were prepared. We need you to specify when
each version was created by date.