Reports
Attorney-ready reports
Initial disclosure — people
ProducibleIndividuals likely to have discoverable information, with contact details and subjects.
Initial disclosure — case‑in‑chief documents
ProducibleDocuments and ESI that may be used to support a claim or defense.
Damages computation
ProducibleEach claimed category, its computation, its inputs and the material behind it.
Documents referred to in the pleadings
ProducibleCategory E, generated from the filed text and added to by hand.
Witness directory
Work productEvery person in the matter with their designations and contact completeness.
Expected testimony report
Work productSummaries with their status: unconfirmed draft, witness confirmed, or attorney approved.
Count-by-count evidence report
Work productEach count with its elements, propositions, documents and witnesses.
Pleading-to-proof matrix
Work productEvery material allegation and what currently stands behind it.
Missing evidence report
Work productOpen gaps, ranked by severity, with the step that would close each one.
Transaction report
Work productEvery recorded movement of funds, fiat and on-chain.
Blockchain transaction report
Work productOn-chain movements with wallet addresses and hashes, and the chains they sit in.
Defamation publication matrix
Work productWho said what, to whom, when, by what means, and what shows falsity and damage.
Master chronology
Work productThe case timeline, with the precision each source actually supports.
Discovery collection status
Work productWhat has been collected, from whom, and how far through review it is.
Privilege log
Work productMaterial withheld or under privilege review. Internal.
Production log
ProducibleWhat has been produced, in which set, and under what Bates range.
Assembled From the Record.Nothing Added That Isn’t Already in the File.
Every report is built from the records as they stand. Where something is unconfirmed, unapproved or undocumented, the report says so rather than filling the gap, and internal reports carry the work-product legend.
Missing evidence report
| Severity | Gap | Attached to | Suggested action | Status |
|---|---|---|---|---|
| Critical | Security alert record for the September 2 export | Count 2 — Misappropriation of Trade Secrets | Ask Ruiz and Meridian's security vendor for any backup of the alert history. | Open |
| High | Bank records have no business-records certification | Count 6 — Unjust Enrichment | Call the bank's legal process unit; if nothing in 10 days, serve a deposition subpoena on the custodian. | In progress |
| High | ¶ 26 may overstate who suppressed the alert | Count 2 — Misappropriation of Trade Secrets | Confirm with Ruiz before relying on ¶ 26; consider amending. | Open |
| High | Identify 'J.M.' in Rennick's Slack | Count 2 — Misappropriation of Trade Secrets | Interrogatory No. 9 to Rennick; check Desai's texts for a first name. | Open |
| High | Farouk's account has no document behind it | Count 4 — Fraudulent Misrepresentation | Ask Farouk whether she kept any email or CRM note; target Halvorsen's CRM in RFP No. 18. | Open |
| High | Rennick's bank records | Count 6 — Unjust Enrichment | Serve subpoena on Rennick's bank; identify bank from wire details. | In progress |
| 6 more open gaps | ||||
Nothing in this report describes missing material as if it existed.
Meridian Analytics v. Halvorsen Data Partners · D. Colo. · 1:26-cv-00614-RMR
Producible or Work Product.Privileged Material Stays Out of Every Export.
Disclosure and production exports leave out privileged, potentially privileged and undetermined material, and no setting can put it back. The privilege log lists what was withheld, and why, as an internal document.
Initial disclosure — documents
| Evidence ID | Description | Custodian | Bates range |
|---|---|---|---|
| MERIDIAN-000001 | Reseller and Implementation Agreement | Dana Whitfield | MER0000001–MER0000002 |
| MERIDIAN-000002 | Mutual Non-Disclosure Agreement | Dana Whitfield | MER0000003 |
| MERIDIAN-000003 | Exhibit C — Quarterly Revenue Report Form | Dana Whitfield | MER0000004 |
| MERIDIAN-000004 | Board appointment letter to Tobias Kane | Dana Whitfield | MER0000005 |
| MERIDIAN-000005 | Minutes of the Board of Directors — June 12, 2024 | Dana Whitfield | MER0000006 |
Privileged, potentially privileged and undetermined material is excluded from this export and cannot be included by any setting on this screen.
Meridian Analytics v. Halvorsen Data Partners · D. Colo. · 1:26-cv-00614-RMR
Privilege log
Internal
- MERIDIAN-000034Withheld
Memorandum — A. Hale to D. Whitfield re claims and early strategy
Attorney-client communication; legal advice on claims and strategy.
Plaintiff's First Production
- MERIDIAN-000032Withheld
Preliminary report — reconstruction of license fees (draft)
Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
Plaintiff's Second Production
- MERIDIAN-000033Withheld
Preliminary code comparison — Tempo v7 and Cadence core (draft)
Draft report of retained expert; work product, Fed. R. Civ. P. 26(b)(4)(B).
Plaintiff's Second Production
Ready to Send.Word, Excel, CSV or Print.
Preview any report in the case, then export it as a Word document, a spreadsheet or a CSV, or print it with the caption.