Free Affidavit - District Court of Connecticut - Connecticut

Case 3:O2—cv-O1573—IV|FiK Document 236-13 Filed O4/20/2007 Page10f4
EXHIBIT 12

Message Case 3:02-cv-01573-MFIK Document 236-13 Filed 04/20/2007 Page 2 of 4Psge 1 ef3
Molot, Richard (USACT)
From: Piermattei, William F. [WFPiermattei@Venab|e.com]
Sent: Monday, April 16, 2007 8:06 AM
To: Molot, Richard (USACT)
Cc: Salcido, Robert; Parker, Bruce R.
Subject: RE; Document production
Rick,
First, could you please explain the relevance of documents regarding a meeting held in November 2005 to this case
(1996-2003)? Second, could you identify those documents you believe are in the custody and control of Dianon that we
have not produced?
-———- Original Message -—-—-
From: Molot, Richard (USACT) [mailto:Richard.Mo|[email protected]]
Sent: Friday, April 06, 2007 3:39 PM
To: Piermattei, William F.
Cc: Davis, Pat (CIV)
Subject: RE: Medicare documents produced to Jim ONeilI
Thanks Bill. If you could send a duplicate of the cd to Pat as well, that would help expedite our review.
Also, I know we briefly spoke a few weeks ago about our outstanding request for production of documents related
to the Hemepath Consensus Conference. As we've mentioned in the past, including in Pat's Nov. 8, 2006 letter to
Robert, our request called for the production of notes and presentation materials, but none of that has been
produced (it is clear from some of the emails you did produce that each laboratory group made presentations at the
meeting). Also, several of the emails indicated that they contained attachments, which were not produced. Please
let me know if you intend to make a complete production of documents/notes/presentation materials related to the
Hemepath Consensus Conference.
Thanks.
Rick
From: Piermattei, William F. [mailto:[email protected]]
Sent: Friday, April 06, 2007 2:54 PM
To: Molot, Richard (USACT)
Subject: RE: Medicare documents produced to Jim ONei|I
I am sending out a cd with all documents with the FOIA contact info today. Bill
-—--- Original Message -----
From: Molot, Richard (USACT) [mailto:[email protected]]
Sent: Thursday, March 29, 2007 2:50 PM
To: Piermattei, William F.
Subject: RE: Medicare documents produced to Jim ONeiII
Bill,
As we discussed today, please send me a set of the documents and we will likely be able to stipulate. Also,
so I have it for my file, could you please send me the name/phone number/reference number of the person
at WPS that O'Neill received the documents from. Thanks.
4/20/2007

M€SSag€Case 3:02-cv-01573-IVIRK Document 236-13 Filed 04/20/2007 Page 3 of 4 Page 2 Oi`3
Rick
From: Piermattei, William F. [mailto:[email protected]]
Sent: Wednesday, March 28, 2007 11:11 AM
To: Molot, Richard (USACF)
Cc: robert salcid 0; Parker, Bruce R.
Subject: Medicare documents produced to Jim ONeill
<>
Rick,
Attached is our proposal that, in lieu of producing the documents CMS/Wisconsin Physician Services
produced to Jim O'NeiII, you stipulate to their authenticity and treat them as if they were produced to Dianon
directly. Please let me know as soon as possible whether you will accept this proposal as our briefs for
discovery sanctions are due April 20th. Thanks, Bill
William Piermattei
Venable, LLP
2 Hopkins Plaza, Suite 1800
Baltimore, Maryland 21201
4‘| 0-244-7473
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