Productions
What has gone out, and what has been held back
| Production | To | Produced | Documents | Withheld | Stamped |
|---|---|---|---|---|---|
| Plaintiff's First Production | Lakeview Partners LLP (counsel for Halvorsen and Kane); Garrow & Finch LLP (counsel for Rennick) | 15 Jun 2026 | 23 | 1 | 23 |
| Plaintiff's Second Production | All counsel of record | Being assembled | 3 | 2 | 0 |
2 production sets in this matter.
Stamped Across the Matter.One Bates Sequence, Never Reused.
Each production records what went out, to whom and when, with the Bates range on every document. Numbering runs across the whole matter and is read from what was actually stamped.
A number is never handed out twice, and a set that has been produced is closed to further change.
Plaintiff's First Production
Served 15 Jun 2026 · Served with Rule 26(a)(1) disclosures.
23 documents · MER0000001 to MER0000024 · 1 withheld and logged
- MER0000001–MER0000002Reseller and Implementation Agreement
- MER0000003Mutual Non-Disclosure Agreement
- MER0000004Exhibit C — Quarterly Revenue Report Form
- MER0000005Board appointment letter to Tobias Kane
- MER0000006Minutes of the Board of Directors — June 12, 2024
- MER0000007Q3 2025 board pack — customer renewal pipeline
- MER0000008Halvorsen quarterly revenue report — Q3 2025
- MER0000009Halvorsen quarterly revenue report — Q4 2025
and 15 more
Assembled, Then Stamped.Gather First, Number When Settled.
Gather the documents for a production, withhold what should not go out, then stamp the rest in one step. Withheld documents stay in the set with their reason.
← Productions
Plaintiff's Second Production
All counsel of record · In preparation. Awaiting Hale's sign-off on the privilege log.
- MERIDIAN-000007Halvorsen quarterly revenue report — Q1 2025Not yet stamped
- MERIDIAN-000008Halvorsen quarterly revenue report — Q2 2025Not yet stamped
- MERIDIAN-000038Directors and officers liability policy — Meridian (2025–2026)Not yet stamped
- MERIDIAN-000032Preliminary report — reconstruction of license fees (draft)Withheld
Logged: Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
- MERIDIAN-000033Preliminary code comparison — Tempo v7 and Cadence core (draft)Withheld
Logged: Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
The Logs, Ready to Serve.Production Log and Privilege Log.
Every produced document with its Bates range, custodian and date, followed by every withheld document with the reason it was withheld, ready to print and serve.
Production log
Plaintiff's First Production
| Bates | Document | Custodian | Date |
|---|---|---|---|
| MER0000001–MER0000002 | Reseller and Implementation Agreement | Dana Whitfield | 18 Mar 2024 |
| MER0000003 | Mutual Non-Disclosure Agreement | Dana Whitfield | 18 Mar 2024 |
| MER0000004 | Exhibit C — Quarterly Revenue Report Form | Dana Whitfield | 18 Mar 2024 |
| MER0000005 | Board appointment letter to Tobias Kane | Dana Whitfield | 3 Jun 2024 |
| MER0000006 | Minutes of the Board of Directors — June 12, 2024 | Dana Whitfield | 12 Jun 2024 |
Privilege log
- MERIDIAN-000034Memorandum — A. Hale to D. Whitfield re claims and early strategy· Avery Hale · 20 Feb 2026
Attorney-client communication; legal advice on claims and strategy.
- MERIDIAN-000032Preliminary report — reconstruction of license fees (draft)· Dr. Samuel Ito · 30 Jul 2026
Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
- MERIDIAN-000033Preliminary code comparison — Tempo v7 and Cadence core (draft)· Hannah Cole · 18 Aug 2026
Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
Withheld, With a Reason.Logged as It Is Withheld.
Withhold a document and give the reason that will appear on the log. It goes on the privilege log at that moment, not at the end.