1

Hammond, Dianne

From: Myers, Sarah Voorhies <myers@chaffe.com>

Sent: Monday, May 17, 2021 1:08 PM

To: Trenton Lacy; Jon Rankin; McIntire, Amy; Hammond, Dianne

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656]

Thanks. As soon as I get a handle on how many emails are included in the production, I’ll be in touch 

regarding a new deposition date. 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Trenton Lacy <trenton@rosslawgroup.com> 

Sent: Monday, May 17, 2021 10:44 AM 

To: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com>; Myers, Sarah Voorhies <myers@chaffe.com> 

Subject: [EXTERNAL] Re: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Sarah, 

I hate to reschedule this deposition once again but I agree the circumstances don't leave for many other 

options. I would agree to an extension of the expert deadline. 

Thanks, 

Trenton 

Sent from my Verizon, Samsung Galaxy smartphone 

Get Outlook for Android

From: Myers, Sarah Voorhies <myers@chaffe.com> 

Sent: Monday, May 17, 2021 10:36:27 AM 

To: Trenton Lacy <trenton@rosslawgroup.com>; Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy 

<mcintire@chaffe.com>; Hammond, Dianne <hammond@chaffe.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656]

Thanks, Trenton. I agree that it makes the most sense to postpone the deposition in the 

circumstances, since we will not have a chance to meaningfully review the documents in advance of 

the Wednesday deposition. But Defendant’s current expert report deadline is June 11th. If we 

reschedule Ms. Soukup’s deposition, I’m not sure that will give us time to retain an expert and secure 

an expert report in advance of the deadline (if we determine that we need an expert after Plaintiff’s 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 1 of 14
2

deposition). Would you be willing to agree to an additional extension of Defendant’s expert report 

deadline? 

Finally, we are happy to supplement our discovery responses if we locate additional responsive 

documents. 

Sarah 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Trenton Lacy <trenton@rosslawgroup.com> 

Sent: Friday, May 14, 2021 9:25 AM 

To: Myers, Sarah Voorhies <myers@chaffe.com>; Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy 

<mcintire@chaffe.com>; Hammond, Dianne <hammond@chaffe.com> 

Subject: [EXTERNAL] RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Sarah, 

I can confirm everything you’ve said: I do not have any legible copies of those emails, and we would not be using legible 

copies should we acquire them in the future without prompt supplementation. I would also insist that, should FSS’s 

review of the email file lead to the discovery of information responsive to our discovery requests, that its responses to 

those requests be supplemented. 

As for leaving the deposition open, I would have to draw the line there. If FSS would like additional time to review the 

emails, we can reschedule once again so y’all can have additional time. Take all the time you need to prepare for her 

deposition, and once you are adequately prepared, we can get it knocked out. If that can’t be done by next week, then 

let’s push it back. 

Thanks, 

Trenton 

From: Myers, Sarah Voorhies <myers@chaffe.com> 

Sent: Thursday, May 13, 2021 5:05 PM 

To: Trenton Lacy <trenton@rosslawgroup.com>; Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy 

<mcintire@chaffe.com>; Hammond, Dianne <hammond@chaffe.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

Hi Trenton,

Thanks for your efforts to sort through this. I wanted to wait to respond to your email from yesterday 

until my IT Department and paralegal were able to download and access the additional information 

that you provided.

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 2 of 14
3

In short, the original document production of bates-numbered documents was 1200 pages – of which 

approximately 100 were illegible. The new link contains thousands of emails, which we cannot 

possibly review in advance of Wednesday’s deposition. However, we have been able to search 

through the newly produced link and access almost all of the illegible documents that you originally 

produced in the bates-numbered responses, with three notable exceptions all of which have the 

subject “Brynne” (see attached PDF). 

Can you please confirm that you cannot provide a legible copy of any of the three attached emails, 

bates-labeled 00439, 00447, 00448? And can you please further confirm that since you do not have 

a legible copy, you will not use any of these emails in the future proceedings, unless legible copies 

are promptly provided to counsel within the pre-trial deadlines and we have the ability to further 

depose Ms. Soukup regarding these documents? And, finally, can you please confirm that you will 

not object to our holding open Ms. Soukup’s deposition based upon the newly-produced emails, since 

we cannot possibly review the new emails in advance of Wednesday’s deposition? Like you, I 

suspect and hope that there is nothing relevant or surprising in these emails, and we will have no 

need to re-depose Ms. Soukup about routine airport operations. 

Happy to further discuss by telephone if that’s easier. 

Thanks,

Sarah 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Trenton Lacy <trenton@rosslawgroup.com> 

Sent: Wednesday, May 12, 2021 9:45 AM 

To: Myers, Sarah Voorhies <myers@chaffe.com>; Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy 

<mcintire@chaffe.com>; Hammond, Dianne <hammond@chaffe.com> 

Subject: [EXTERNAL] RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Sarah, 

It sounds like y’all are having the same trouble as us. Unfortunately, what we sent you was the result of our attempt to 

access the original production and convert the original files. We put the files through a converter and produced the 

same result it gave us: you have everything that we have. If your IT people are saying there are more documents in the 

file, then I’ve never laid eyes on them and didn’t know they existed. 

But even if we could open the e-mails, I don’t believe it would help to only produce responsive e-mails: each and every 

email in there would likely be responsive to the requests as written, including “Please produce any and all documents 

and communications related to Plaintiff’s job duties as Regional Director of Operations for FSS” and “Please produce any 

and all documents and communications related to Plaintiff’s job performance.” 

Ultimately, my understanding is that all of these emails were sent to/from Ms. Soukup using her FSS email account. My 

understanding is also that FSS cut off her access to that email account. We have already incurred significant time and 

expense trying to access the emails and have provided FSS with everything that we have. I want to be accommodating, 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 3 of 14
4

but it seems to me that FSS has: (1) actively prevented Ms. Soukup from accessing her work emails; (2) greater access to 

her work e-mails that she does; yet (3) demanded that she nonetheless produce her work emails in its preferred format 

at her own expense. 

Let me know what else we can do to accommodate FSS. If you’d like to serve some interrogatories or requests for 

admission asking her to affirm that she has no correspondences responsive to FSS’s requests other than what she’s 

provided, I’d be happy to respond to that. If FSS has a particular concern in mind (e.g. she used her work email 

improperly), then let’s talk about requests that may be able to address those concerns. Ultimately, I’d like to do what I 

can to address this because I have no desire to engage in a lengthy discovery battle over what are almost certainly 

mundane e-mail concerning airport operations. 

Thanks, 

Trenton N. Lacy

Attorney at Law

512-474-7677 | Office

512-474-5306 | Facsimile

Trenton@RossLawGroup.com

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: Myers, Sarah Voorhies <myers@chaffe.com> 

Sent: Tuesday, May 11, 2021 1:55 PM 

To: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

Hi Jon and Trenton,

I wanted to follow up about supplemental document production. My IT Department still is trying to 

access the documents – but they think it appears to be more than 20,000 emails. As you know, the 

original production was roughly 1200 pages. Can you please explain the discrepancy?

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 4 of 14
5

Is there a way that someone in the Texas office can access the original production and convert the 

original files – and send to us? Or can you only send the responsive documents to us?

Thanks,

Sarah 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Myers, Sarah Voorhies <myers@chaffe.com> 

Sent: Monday, May 10, 2021 5:07 PM 

To: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

See attached re-notice of deposition, which we hope can proceed for next Wednesday. 

That being said, we still haven’t been able to access the documents, but my IT Director advises that 

the shared folder seems to have more than 21,000 emails. Is this accurate? Plaintiff only produced 

roughly 1200 pages of documents in its discovery responses. 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Jon Rankin <jrankin@rosslawpc.com> 

Sent: Monday, May 10, 2021 1:05 PM 

To: Myers, Sarah Voorhies <myers@chaffe.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: [EXTERNAL] RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Counsel:

I’ll try re-sharing the folder. You should receive another email shortly.

Jon D. Rankin

Paralegal

512-474-7677 | Office

512-474-5306 | Facsimile

Jon@RossLawGroup.com

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 5 of 14
6

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: Myers, Sarah Voorhies [mailto:myers@chaffe.com] 

Sent: Monday, May 10, 2021 1:00 PM 

To: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

We still haven’t received the documents. What time did you send, so I can follow up with my IT 

Department? 

We will issue a new notice of deposition for next Wednesday.

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Jon Rankin <jrankin@rosslawpc.com> 

Sent: Monday, May 10, 2021 12:34 PM 

To: Myers, Sarah Voorhies <myers@chaffe.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: [EXTERNAL] RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Counsel:

Mr. Lacy and our client are available on Wednesday, May 19, 2021.

Were you able to get the .olm file opened?

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 6 of 14
7

Jon D. Rankin

Paralegal

512-474-7677 | Office

512-474-5306 | Facsimile

Jon@RossLawGroup.com

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: Myers, Sarah Voorhies [mailto:myers@chaffe.com] 

Sent: Monday, May 10, 2021 12:10 PM 

To: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

Hi Jon,

I still don’t have the documents. Once they are received, it will take some time for us to convert the 

documents – or my paralegal indicates that we may need Ms. Soukup to reload them to a separate 

link. 

At this point, I think we need to discuss alternate dates for the deposition. Please let me know 

Trenton and Ms. Soukup’s availability for next week, particularly next Wednesday, May 19th. 

Thanks.

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 7 of 14
8

From: Jon Rankin <jrankin@rosslawpc.com> 

Sent: Monday, May 10, 2021 10:34 AM 

To: McIntire, Amy <mcintire@chaffe.com>; Myers, Sarah Voorhies <myers@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: [EXTERNAL] RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Counsel:

I am uploading the raw “.olm” file containing our client’s email communications. It will take a few minutes to finish 

uploading it because it is so large (5gb). You should be able to download and view it shortly. Please let us know if you 

are still having issues with the legibility of the emails.

Jon D. Rankin

Paralegal

512-474-7677 | Office

512-474-5306 | Facsimile

Jon@RossLawGroup.com

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: Jon Rankin 

Sent: Friday, May 7, 2021 1:03 PM 

To: McIntire, Amy <mcintire@chaffe.com>; Myers, Sarah Voorhies <myers@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Trenton Lacy <trenton@rosslawgroup.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

Counsel:

Attached hereto are:

1. Plaintiff First Amended Responses and Objections to Defendant’s First Set of Interrogatories;

2. Plaintiff’s First Supplemental Responses to Defendant’s Request for Production of Documents; and 

3. Documents labelled SOUKUP 01185-01192.

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 8 of 14
9

Jon D. Rankin

Paralegal

512-474-7677 | Office

512-474-5306 | Facsimile

Jon@RossLawGroup.com

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: McIntire, Amy [mailto:mcintire@chaffe.com] 

Sent: Monday, May 3, 2021 7:24 PM 

To: Trenton Lacy <trenton@rosslawgroup.com>; Myers, Sarah Voorhies <myers@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Jon Rankin <jrankin@rosslawpc.com> 

Subject: RE: v. FSS Soukup [CMNO-ChaffeDMS.FID297656] 

Hi Trenton,

To follow-up on our discovery teleconference last Friday, we noticed that there may have been some conversion 

issues with some of the emails produced in the bulk PDF. For one example, SOUKUP00439-442 looks to be 

emails that were mis-converted during production (perhaps sent from a MAC and opened on a PC?) and are 

now illegible in the produced PDF. This seems to have happened several times throughout the 

production. Can you please supplement to produce these emails in a more legible format? I think you had 

mentioned on the phone about some formatting issues that might be resolved when Plaintiff provides her 

supplemental responses, so you may already be aware of this, but I wanted to bring to your attention in case 

not. 

Also, just to confirm our teleconference last Friday, I think we reached an amicable agreement on everything 

outlined in the Rule 37 Letter. For the requests for production generally, Plaintiff agreed to supplement her 

responses to organize the produced documents by folder/placeholder/etc. and to specify which document(s) are 

responsive to each request. If Plaintiff has no documents responsive to a specific request, then Plaintiff agreed 

to state so. For RFP 34, Plaintiff agreed to supplement her response subject to the following modification (or 

something substantially similar) of the request: “[t]o the extent not already produced in response to the 

foregoing Requests, please produce any document that you believe supports the specific factual allegations 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 9 of 14
10

alleged in your Amended Complaint.” For RFP 35, Plaintiff agreed to supplement her response subject to the 

following modification (or something substantially similar) of the request: “[t]o the extent not already produced 

in response to the foregoing Requests, please produce any document that you believe supports all or part of the 

claims of discrimination and retaliation alleged in your Amended Complaint.” 

For the interrogatories generally, Plaintiff agreed to provide a verification. Plaintiff further agreed to 

supplement her responses to IROG Nos. 1, 4, and 19 as requested in the Rule 37 Letter. For IROG No. 7, 

Plaintiff agreed to describe to the best of her recollection the investigation conducted by Frontier and/or to 

describe the documents that she believes evidence the investigation by Frontier. For IROG No. 13, Plaintiff 

agreed to supplement her response to qualitatively (and not quantitatively) describe her non-economic 

damages. For IROG No. 20, Plaintiff agreed to supplement her response to describe the jobs she applied to 

following the end of her employment with FSS and to provide her work search records from the Texas 

Workforce Commission when received. For IROG No. 22, no supplemental response is required as Plaintiff 

has stated in her response that she has no responsive documents in her possession. Given the upcoming 

deposition, Plaintiff agreed to supplement her responses by 5/7/20. Please let me know if you disagree with any 

of my above recollection, and I’m also happy to discuss.

Thanks,

Amy

. 

Amy L. McIntire | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7030 | f: 504-544-6090 

chaffe.com | linkedin | bio | vcard | email 

From: McIntire, Amy 

Sent: Friday, April 30, 2021 1:11 PM 

To: 'Trenton Lacy' <trenton@rosslawgroup.com>; Myers, Sarah Voorhies <myers@chaffe.com>; Hammond, Dianne 

<hammond@chaffe.com> 

Cc: Jon Rankin <jrankin@rosslawpc.com> 

Subject: RE: Soukup v. FSS [CMNO-ChaffeDMS.FID297656] 

Hi Trenton,

Sarah had a conflict come up, so I’ll be stepping in for her on the call. No problem re: the mix up. If 

you could call my direct dial (504-585-7030) in about 30 minutes that would be great.

Thanks, 

Amy

Amy L. McIntire | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7030 | f: 504-544-6090 

chaffe.com | linkedin | bio | vcard | email 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 10 of 14
11

From: Trenton Lacy <trenton@rosslawgroup.com> 

Sent: Friday, April 30, 2021 1:08 PM 

To: Myers, Sarah Voorhies <myers@chaffe.com>; Hammond, Dianne <hammond@chaffe.com> 

Cc: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com> 

Subject: [EXTERNAL] RE: Soukup v. FSS [CMNO-ChaffeDMS.FID297656] 

This Message originated outside of Chaffe McCall's system.

Sarah, 

My apologies, it sounds like there was a scheduling mixup that was 100% the fault of my office. If you’d be available, I 

can meet with you here in about 30 minutes, but if that doesn’t work then I’d be happy to make myself available at your 

earliest convenience. Again, I apologize. 

Thanks, 

Trenton 

From: Myers, Sarah Voorhies <myers@chaffe.com> 

Sent: Monday, April 26, 2021 4:12 PM 

To: Trenton Lacy <trenton@rosslawgroup.com>; Hammond, Dianne <hammond@chaffe.com> 

Cc: Jon Rankin <jrankin@rosslawpc.com>; McIntire, Amy <mcintire@chaffe.com> 

Subject: RE: Soukup v. FSS [CMNO-ChaffeDMS.FID297656] 

Thanks, Trenton. No problem at all to reschedule; I just wanted to get the conversation started. Let’s 

plan to talk on Friday afternoon at 1:00 p.m. 

Sarah 

Sarah Voorhies Myers | Partner 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7009 | f: 504-544-6092 

chaffe.com | linkedin | bio | vcard | email 

From: Trenton Lacy <trenton@rosslawgroup.com> 

Sent: Monday, April 26, 2021 3:47 PM 

To: Hammond, Dianne <hammond@chaffe.com> 

Cc: Myers, Sarah Voorhies <myers@chaffe.com>; Jon Rankin <jrankin@rosslawpc.com> 

Subject: [EXTERNAL] RE: Soukup v. FSS 

This Message originated outside of Chaffe McCall's system.

Sarah, 

Thank you for reaching out. I’d be happy to meet and confer about our discovery responses, and I’m willing to 

supplement where appropriate, but you’ve notified me of this dispute a mere 48 hours before the arbitrary date and 

time of a discovery conference that you’ve apparently scheduled with me--without my input. I’m currently preparing for 

a mediation on a separate case, scheduled for tomorrow, and I’m unlikely to have time to consider this request for 

supplementation until Wednesday morning at the earliest. 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 11 of 14
12

If you’d be amenable, I’m available pretty much any time Thursday (April 29th) or Friday (April 30th) after 12:00 PM CST, 

and I’d be happy to discuss this with you any time those afternoons. If that doesn’t work for you, I can see about doing 

something this weekend or early next week. 

Thanks, 

Trenton N. Lacy

Attorney at Law

512-474-7677 | Office

512-474-5306 | Facsimile

Trenton@RossLawGroup.com

1104 San Antonio Street

Austin, Texas 78701

www.RossLawGroup.com

This message is intended only for the person(s) to whom it is addressed and may contain privileged, confidential, and/or insider information. If you 

have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Any disclosure, 

copying, distribution, or taking of any action concerning the contents of this message and any attachment(s) by anyone other than the named recipient(s) 

is strictly prohibited. Sending an instant message or e-mail and/or receipt of a response does not create an Attorney-Client relationship or constitute the 

formation of a contract. No obligation is created on the part of the sender or the recipient. A contract of representation can only be created by signature 

of an Attorney-Client Agreement.

From: Hammond, Dianne <hammond@chaffe.com> 

Sent: Monday, April 26, 2021 3:20 PM 

To: Trenton Lacy <trenton@rosslawgroup.com> 

Cc: Myers, Sarah Voorhies <myers@chaffe.com> 

Subject: Soukup v. FSS 

Please see the attached. 

Dianne M Hammond | Legal Secretary 

1100 Poydras Street, Suite 2300 

New Orleans, LA 70163 

o: 504-585-7012 | f: 504-585-7075 

chaffe.com | linkedin | email 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, is intended for 

use only by the addressee(s) named herein and contains confidential and/or privileged information. Any unauthorized 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 12 of 14
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review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please notify the 

sender immediately by reply e-mail or telephone and delete the original and destroy all electronic and other copies of 

this message. If you are the intended recipient but do not wish to receive communications through this medium, please 

so advise the sender immediately. (*Scanned by Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, is intended for 

use only by the addressee(s) named herein and contains confidential and/or privileged information. Any unauthorized 

review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please notify the 

sender immediately by reply e-mail or telephone and delete the original and destroy all electronic and other copies of 

this message. If you are the intended recipient but do not wish to receive communications through this medium, please 

so advise the sender immediately. (*Scanned by Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, 

is intended for use only by the addressee(s) named herein and contains confidential and/or privileged 

information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the 

intended recipient, please notify the sender immediately by reply e-mail or telephone and delete the original and 

destroy all electronic and other copies of this message. If you are the intended recipient but do not wish to 

receive communications through this medium, please so advise the sender immediately. (*Scanned by 

Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, 

is intended for use only by the addressee(s) named herein and contains confidential and/or privileged 

information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the 

intended recipient, please notify the sender immediately by reply e-mail or telephone and delete the original and 

destroy all electronic and other copies of this message. If you are the intended recipient but do not wish to 

receive communications through this medium, please so advise the sender immediately. (*Scanned by 

Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, 

is intended for use only by the addressee(s) named herein and contains confidential and/or privileged 

information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the 

intended recipient, please notify the sender immediately by reply e-mail or telephone and delete the original and 

destroy all electronic and other copies of this message. If you are the intended recipient but do not wish to 

receive communications through this medium, please so advise the sender immediately. (*Scanned by 

Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, is intended for 

use only by the addressee(s) named herein and contains confidential and/or privileged information. Any unauthorized 

review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please notify the 

sender immediately by reply e-mail or telephone and delete the original and destroy all electronic and other copies of 

this message. If you are the intended recipient but do not wish to receive communications through this medium, please 

so advise the sender immediately. (*Scanned by Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, is intended for 

use only by the addressee(s) named herein and contains confidential and/or privileged information. Any unauthorized 

review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please notify the 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 13 of 14
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sender immediately by reply e-mail or telephone and delete the original and destroy all electronic and other copies of 

this message. If you are the intended recipient but do not wish to receive communications through this medium, please 

so advise the sender immediately. (*Scanned by Mimecast*) 

Chaffe McCall L.L.P. CONFIDENTIALITY NOTICE: This e-mail transmission, including attachments, if any, 

is intended for use only by the addressee(s) named herein and contains confidential and/or privileged 

information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the 

intended recipient, please notify the sender immediately by reply e-mail or telephone and delete the original and 

destroy all electronic and other copies of this message. If you are the intended recipient but do not wish to 

receive communications through this medium, please so advise the sender immediately. (*Scanned by 

Mimecast*) 

Case 1:20-cv-00648-RP Document 37-1 Filed 06/03/21 Page 14 of 14