Eugene F. Assaf, P.C. 

To Call Writer Directly: 

(202) 879-5196 

eugene.assaf@kirkland.com 

655 Fifteenth Street, N.W. 

Washington, D.C. 20005 

(202) 879-5000 

www.kirkland.com 

Facsimile: 

(202) 879-5200 

Beijing Boston Chicago Hong Kong Houston London Los Angeles Munich New York Palo Alto San Francisco Shanghai 

November 8, 2017 

VIA E-MAIL 

Christopher M. Placitella 

Cohen, Placitella & Roth, P.C. 

127 Maple Avenue 

Red Bank, NJ 07701 

Brendan E. Little 

Levy Konigsberg LLP 

800 Third Avenue, 11th Fl. 

New York, NY 10022 

Re: Kimberlee Williams, et al. v. BASF Catalysts LLC, et al.

Dear Messrs. Placitella and Little: 

We write to address apparent deficiencies in your November 2 and November 3 document 

productions. As you are aware, the Special Discovery Master ordered you to produce or log, 

among other materials, the complete client files for all six named plaintiffs and the complete client 

files for all putative class members represented by the Early Law Firm. See ECF No. 360 at 2-3; 

ECF No. 361 at 2-3. The deadline for production of these materials was November 2, 2017. 

However, it appears that your document production is incomplete. 

First, with respect to Roseanne Chernick, it appears plaintiffs’ document production was 

limited to some 260 documents. Over the past year, however, you have repeatedly told us that the 

Early Firm’s file for the Chernick case is voluminous due to the length of time that case has been 

pending. Indeed, as of this past August, you still were treating the Chernick file as a special case, 

in contrast to the files for the five other plaintiffs. See 8/18/17 C. Placitella Ltr. to E. Assaf at 2. 

We therefore expected to receive more than 260 documents. Please confirm you have produced 

the entire file and are not withholding any remaining materials from the file. To the extent you 

are, in fact, withholding materials from Ms. Chernick’s file, please state the basis for doing so. 

Second, the Early Firm was ordered to produce or log all of its client files for all putative 

class members by November 2, 2017. See ECF No. 361 at 2-3. To date, we have received what 

appears to be only a portion of Roseanne Chernick’s file. We understand that Early has at least 

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Christopher M. Placitella 

Brendan E. Little 

November 8, 2017 

Page 2 

three more relevant client files in its possession, see 10/26/17 Hr’g Tr. at 153:12 - 154:6, and your 

failure to produce them is a violation of the Special Discovery Master’s Order. Please confirm 

that you will produce the remaining client files no later than November 9, 2017. 

Finally, with respect to all six named plaintiffs, your November 2 and November 3 

document productions include fewer than ten e-mails in total. Please confirm that you have 

produced all e-mails related to the named plaintiffs’ cases, including internal e-mail 

correspondence within the Bevan Firm and the Early Firm, and are not withholding any such 

materials. To the extent you are, in fact, withholding e-mails related to the named plaintiffs’ cases, 

please state the basis for doing so. 

 We look forward to your response. 

Sincerely, 

/s/ Eugene F. Assaf, P.C. 

Eugene F. Assaf, P.C. 

cc: Counsel for all parties 

Case 2:11-cv-01754-BRM-AME Document 372-8 Filed 11/13/17 Page 2 of 2 PageID: 15503