Extract to table

Fifth, we must build the evidentiary record necessary to support RGC's request for injunctive relief

Actual Malice / Reckless Disregard To prevail on our trade libel claim, we must demonstrate that GPR published its reports with knowledge of their falsity or with reckless disregard for the truth

GPR's Financial Profile and Ability to Pay In connection with our damages analysis and any potential settlement discussions, we must also develop a clear picture of GPR's financial profile and ability to satisfy a judgment

This deposition will be noticed to GPR with a detailed list of topics for which the entity must designate a witness or witnesses prepared to testify on its behalf

We must prepare these witnesses for defensive depositions while also considering their potential use as affirmative witnesses at trial

• Metadata preservation requirements: The protocol will specify the minimum metadata fields that must be preserved and produced, including date created, date modified, author, recipients, subject line, and file path