EXHIBIT U

Case: 19-30088 Doc# 2460-22 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 1

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Minga, Jay

From: Julian, Robert <rjulian@bakerlaw.com>

Sent: Saturday, May 25, 2019 6:39 PM

To: Slack, Richard

Cc: Jones, Hannah L.; Liou, Jessica; lgrossbard@cravath.com; Singh, David; David Herman; 

Peter Benvenutti; Karotkin, Stephen; Monica Kozycz; Kristiansen, Eric; Jane Kim 

(jkim@kellerbenvenutti.com); Kramer, Kevin

Subject: Re: Order After May 8 Discovery Hearing

Richard,  

That agreement and order are acceptable. 

Thanks, 

Robert Julian  

Partner 

Baker Hostetler 

1160 Battery St. 

Suite 100 

San Francisco, CA 

Tel: 415 806 6000 

rjulian@bakerlaw.com

bakerlaw.com

On May 24, 2019, at 3:35 PM, Slack, Richard <richard.slack@weil.com> wrote: 

Bob,

The Court did not address the time for production at the hearing and did not instruct the 

parties to include a production timeline in the Order. We therefore do not believe that the 

Order should have any such date because it is intended to reflect the actual rulings of the Court 

at the hearing.  

Nevertheless, the Debtors are prepared to work with you on reasonable production dates.  We 

propose that we will make our first rolling production responsive to both the 2004 Application 

and the management‐related requests 15 days from the date of entry of the Order.  The 

Debtors will then produce additional responsive documents to such requests on a rolling basis, 

and make a reasonable, good faith effort to complete production within 30 days of the date of 

its first production.  The time is reasonable and necessary given the volume of the requests, 

including, for example, that the requested board materials span 3 years, are highly sensitive 

and will need to be carefully reviewed for privilege, and the contractor information spans 10 

years and many miles of wires.  

Please let us know if the TCC is signed off on the Order so we can submit to the Court or if there 

is anything further to discuss regarding production timeline issues.  

Thanks,

Case: 19-30088 Doc# 2460-22 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 2

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Richard

From: Julian, Robert <rjulian@bakerlaw.com>  

Sent: Thursday, May 23, 2019 4:33 PM 

To: Jones, Hannah L. <Hannah.L.Jones@weil.com> 

Cc: Liou, Jessica <jessica.liou@weil.com>; lgrossbard@cravath.com; Singh, David 

<David.Singh@weil.com>; David Herman <DHerman@cravath.com>; Peter Benvenutti 

<pbenvenutti@kellerbenvenutti.com>; Slack, Richard <richard.slack@weil.com>; Karotkin, Stephen 

<stephen.karotkin@weil.com>; Monica Kozycz <mkozycz@cravath.com>; Kristiansen, Eric 

<EKristiansen@bakerlaw.com> 

Subject: RE: Order After May 8 Discovery Hearing 

  

Hannah, 

The Order is fine, however we need a production date in the order. My order said 15 days from the date 

of the order. We suggest that date. My email on this did not go out last week, sorry. So would you 

please advise us tomorrow? 

Thanks, 

Bob 

  

From: Jones, Hannah L. <Hannah.L.Jones@weil.com>  

Sent: Thursday, May 16, 2019 4:01 PM 

To: Julian, Robert <rjulian@bakerlaw.com>; Kristiansen, Eric <EKristiansen@bakerlaw.com>; Woltering, 

Catherine E. <cwoltering@bakerlaw.com> 

Cc: Liou, Jessica <jessica.liou@weil.com>; lgrossbard@cravath.com; Singh, David 

<David.Singh@weil.com>; David Herman <DHerman@cravath.com>; Peter Benvenutti 

<pbenvenutti@kellerbenvenutti.com>; Slack, Richard <richard.slack@weil.com>; Karotkin, Stephen 

<stephen.karotkin@weil.com>; Monica Kozycz <mkozycz@cravath.com> 

Subject: Order After May 8 Discovery Hearing 

  

All, 

  

Please find attached the draft proposed order in connection with the May 8 discovery 

conference.  Please let us know if the TCC has edits or is signed off. 

  

Best,  

Hannah 

<image001.jpg>

Hannah L. Jones

Associate 

Weil, Gotshal & Manges LLP 

201 Redwood Shores Parkway 

Redwood Shores, CA 94065-1134 

Hannah.L.Jones@weil.com

+1 650 802 3137 Direct

  

  

Case: 19-30088 Doc# 2460-22 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 3

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Case: 19-30088 Doc# 2460-22 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 4

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