Beruflich Dokumente
Kultur Dokumente
Defendants MJJ Productions, Tna. and MJJ Ventures, Inc.s Notice of Motion and Motion
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3 to Compel Wade Robson's Compliance In Producing Documents and fox Sanctions(the
5 Katherine Kieindienst from Kinsella Weitzman Iser Kump 8c Aldisert LLP appeared on behalf of
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6 Defendants MJJ Productions, Inc. and MJJ Ventures,Inc.("Defendants"}. Vince Finaldi and Alex
7 Canny appeared on behalfofPIaintzff Wade Robson("Robson"). The Court has reviewed the
8 papers associated with the Motion and the additional information and argument presented by
9 counsel at the time ofthe hearing. For good cause, the Court orders as follows:
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~o 1. Robson shall produce all responsive documents in his possession, custody, and
I1 cont~-o1 that he agxeed to produce in his June 3,2016 verified response and/or his July 26,2016
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12 verifed. amended response to the First Set ofRequests far Production of Documents and.Things
13 propounded by MJJ Productions, Ti c. on or befare March 1,2017(the "Production"~, including
1.5 attachments, detemune whether those attachments are available and accessible, and shall
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17 reproduce all previously produced emails that were missing attachments in full and complete form,
20 to/from/cc'ed/bcc'ed to any members of his family (including, but not limited to parents,
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23 ~ tolfrom/ce'ed/bce'ed to Helen Yu where a third party, who is not a lawyer, is the author or a
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24 recipient ofthe email, including but not limited to all emails to/from/cc'ed/bce'ed to Alan Nevins.
27 with all electronically stored information and metadata intact. The parties shall meet and confer
28 regarding payment for the production of electronically stored information and metadata;
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[PROPOSED)ORUBR-
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1 6. Robson shall prepare and sign a declaration detailing:(a} all steps lie took to search
2 for and locate responsive documents fox production;(b)the reasons for why soma emails(if any)
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3 produced by 3oey Robson(Rabson's mother)and Chantal Robson(Robson's sister), where
4 Robson is an author, recipient or is copied, have not been located; and(c)all steps,if any, he has
5 taken to preserve potentially responsive documents since the filing ofthis litigation. T~iis
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6 declaration shall be provided to Defendants with Rabson's Production;
7 7. Defendants' request for athird-party forensic examination ofRobson's aamputers,
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14 THE HON.MITCHELL L. BECKLOFF
JUDGE OF THE SUPERIOR COURT
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APPROVED AS TO FORM ONLY BY:
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2I MANLY,STEWART &
KINSELLA WEITZMAN ISER KUMP &
22 ALDISERT,LLP
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E. Canny
24 Jonathan P. Steinsapir
Attorneys for Defendants Attorneys for F
zs MJJ Productions,Inc, and M3J Ventures, Inc. Wade Robsor~
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[PROPOSED]ORDER