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Contract analysis / cross-motion-memo-of-law.docx
cross-motion-memo-of-law.docx
High · 1
Medium · 0
Standard · 1
1. Compelling Plaintiff Meridian Infrastructure Partners LLC to produce all 187 documents
1. Compelling Plaintiff Meridian Infrastructure Partners LLC to produce all 187 documents improperly withheld under the common interest privilege, as the privilege does not apply to communications between Meridian and its financial investor, Ridgepoint Capital Group LP;
2. In the alternative, directing Meridian to produce the approximately 112 documents that
2. In the alternative, directing Meridian to produce the approximately 112 documents that do not involve any attorney on the communication, and ordering in camera review of the remaining approximately 75 documents to determine privilege applicability;
3. Awarding NFA its reasonable costs and attorneys' fees incurred in connection with this
Standard
⚑ Commercial term
3. Awarding NFA its reasonable costs and attorneys' fees incurred in connection with this cross-motion; and
4. Granting such other and further relief as the Court deems just and proper.
High
⚑ Non-compete / exclusivity restraint
4. Granting such other and further relief as the Court deems just and proper. Dated: New York, New York December 6, 2024 CALDERWOOD & HARKNESS LLP By: ________ Linda Osei Responsible Partner Jeffrey Park Lead Associate 425 Park Avenue, 33rd Floor New York, NY 10022 Telephone: (212) 558-4000 Attorneys for Defendant Northgate Fiber Americas Inc. C&H Matter No. 1022-00005 CERTIFICATION OF WORD COUNT / COMPLIANCE I, Jeff