Misc | Filed: October 02, 2026
| Entered: October 02, 2026
Ly v. EBSCO Industries, Inc. et. al.
Civil Rights: Other | Massachusetts
Declaration
DECLARATION re 209 First MOTION to Compel PLAINTIFFS MEMORANDUM OF LAW IN SUPPORT OF HIS MOTION UNDER FED. R. CIV. P. 37(a)(3)(B) AND 37(a)(4) TO COMPEL COMPLETE, VERIFIED, PARTY-SPECIFIC INTERROGATORY ANSWERS AND DOCUMENT PRODUCTION, 210 Appendix/Exhibit,, 208 First MOTION to Compel PLAINTIFFS MOTION UNDER FED. R. CIV. P. 37(a)(3)(B) AND 37(a)(4) TO COMPEL COMPLETE, VERIFIED, PARTY-SPECIFIC INTERROGATORY ANSWERS AND DOCUMENT PRODUCTION; RULE 33(d) DESIGNATIONS; RULE 34 RESPONSES AND PRODUCTION; A RULE 26( IN SUPPORT OF PLAINTIFFS MOTION TO COMPEL COMPLETE, VERIFIED, PARTY-SPECIFIC DISCOVERY RESPONSES AND PRODUCTION by Mohamed Ly. (Attachments: # 1 Exhibit Plaintiffs First Set of Interrogatories (Nos. 125) and First Requests for Production (Nos. 132), # 2 Exhibit Defendants June 3, 2026 Answers to Interrogatories, with Verification, # 3 Exhibit Defendants June 3, 2026 Responses to Requests for Production, # 4 Exhibit Defendants Production Index and Bates-Stamped Documents, EBSCO000001078, # 5 Exhibit Plaintiffs June 29, 2026 Master Deficiency Ledger and July 31, 2026 Notice of Deficiencies, # 6 Exhibit Defense Counsels July 30, 2026 Correspondence Concerning Rule 33(d) and Bates Chart, # 7 Exhibit Plaintiffs August 14, 2026 Consolidated Rule 37.1 Conferral and Demand, # 8 Exhibit Defense Counsels August 27, 2026 Letter Concerning Bates Chart, Narrowed Scopes, and Responses, # 9 Exhibit Plaintiffs September 15, 2026 Supplemental-Responses Correspondence, # 10 Exhibit Plaintiffs September 28, 2026 Final Rule 37.1 Conferral and Demand for Cure Concerning EBSCO000076, # 11 Exhibit September 29, 2026 ESI-Vendor Quotation, Plaintiffs Rejection of Proposed Gating Condition, and Notice of Continuing Default, # 12 Exhibit September 29, 2026 Defense Correspondence Reiterating ESI-Vendor Demand as a Compliance Precondition, # 13 Exhibit Plaintiffs October 2, 2026 Rejection of Defendants ESI-Vendor Precondition, # 14 Exhibit Plaintiffs September 2, 2026 Conferral Concerning Outstanding ROG/RFP Matters, # 15 Exhibit Plaintiffs September 4, 2026 Conferral Concerning Outstanding ROG/RFP Matters, # 16 Exhibit Plaintiffs September 28, ... (truncated)