On December 10, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Pleasant, Christopher,
Trahan, David,
and
Asgard Us,
Boe Exploration & Production Llc,
Transocean Offshore Deepwater Drilling Inc,
Beacon Offshore Energy Llc,
Transocean Drilling,
Triton Voyager Asset Leasing Gmbh,
Triton Voyager Asset Leasing Gmbh , Asgard Us,
for MDL - Hurricane
in the District Court of Harris County.
Preview
Joseph Canida
From: Tim Strickland
Sent: Thursday, March 21, 2024 9:16 AM
To: Roland Christensen; Caj Boatright; Kurt Arnold
Cc: Shahmeer Halepota; Tod Everage; Laura Dumas; Joseph Canida
Subject: Asgard- Glass Supplemental Production
Attachments: Glass 2024.02.21 - MDL - 11-56 am-TWS to A&I re Glass Deficient Discovery.pdf
Gents,
See attached letter dated 21 February 2024 seeking supplemental discovery from Mr. Glass. We
mentioned this briefly during the 1 March 2024 status conference with Judge Collier.
We kindly request that Mr. Glass supplement his production.
Do not hesitate to contact me if you have any questions.
Tim Strickland
Partner
713.844.3031 (direct)
281.380.0569 (mobile)
TIMOTHY W. STRICKLAND, PARTNER
PH 713.844.3031
TIM.STRICKLAND@KEANMILLER.COM
February
Via Service
Roland Christensen rchristensen@arnolditkin.com
Mr. Caj Boatwright cboatright@arnolditkin.com
Mr. Kurt Arnold karnold@arnolditkin.com
ARNOLD & ITKIN
6009 Memorial Drive
Re: Hurricane Zeta Litigation
MDL 113th Judicial District Court for Harris County, Texas
Case No: 2022
Bradford Glass vs. Transocean Drilling (U.S.A.), Inc., et al. Judicial
District Court for Harris County, Texas
Case No.: 202
File No.
Dear Counsel
I am writing regarding multiple deficiencies identified in Plaintiff’s Discovery Responses to
Transocean as identified below:
Plaintiff’s Responses to Transocean’s First Set of Discovery
Request for Production No. 21 & 22 Transocean requested that Plaintiff produce copies of all
photographs, videotapes, or motion pictures of Plaintiff taken since the date of the incident relating to any
aspect of this lawsuit, and any media that allegedly depict the incident or any damages claimed by Plaintiff.
Plaintiff indicated in his response that he would supplement all responsive media in his possession, but
Transocean still has not received any relevant responsive production to date Please supplement with all
responsive photographs and motion pictures in Plaintiff’s possession.
Further, as you recall from the deposition of Eliana Glass, Plaintiff’s spouse, on February 13, 2024,
she testified that the Glass’ have gone on multiple trips and family vacations since the date of the incident,
serving as chaperones for their daughter, Jordan G senior trip to the Dominican Republic
on or around Spring 2023. Include in your supplemental production photographs and motion pictures
taken of Plaintiff during the family’s travels as Ms. Glass testified to in her deposition, as it relates to
Page
Plaintiff alleged damages regarding his quality of life and enjoyment of leisure activities since the date
of the alleged incident.
Requests for Production Nos. 27, 58, Transocean also requested the production of all posts
and photographs posted to any Facebook, Instagram, or Twitter account om October 1, 2020 through the
present, along with account data from October 1, 2020 through the present for any Facebook account
maintained by Plaintiff. Plaintiff did not provide an adequate response, merely inserting blanket objections
to each request. Please produce the requested documents and information.
Request for Production No. Pertaining to any item of cure Plaintiff contends Transocean has
failed to pay, Transocean requested Plaintiff to produce documents substantiating that Transocean
received notice that cure was owed for each such item Plaintiff stated he will produce all billing records,
which is not with this request is seeking. Please supplement with the requested documents or amend the
response accordingly.
Requests for Production No. 65 & Plaintiff objected to Transocean’s request f any written or
recorded statement of aintiff or any representative f Plaintiff, along with any Transocean agent,
employee, or representative in Plaintiff’s possession, stating th are duplicative request when y are
in fact not. Please supplement with any and all responsive documents and correspondence in Plaintiff’s
possession, custody, or control.
Request for Production No. 99 Plaintiff stated he produced all responsive documents in his
possession. However, Eliana Glass testified in her deposition that she owns and operates a Pump It Up
franchise party event center in Brandon, Mississippi Ms. Glass further testified that the legal name of the
business is G&A Entertainment, LLC. Filings obtained from the Mississippi Secretary of State for G&A
Entertainment, LLC indicate that Plaintiff has been manager of the business since its formation in
, while Ms. Glass has been acting as a Managing Member. Therefore, please produce all responsive
federal and state business tax filings for G&A entertainment, LLC, as it pertains to a business interest
owned by Plaintiff.
Plaintiff’s Responses to Transocean’s Second Set of Discovery
nterrogatory No. 1 Transocean requested all cell phone numbers and corresponding service
providers used by Plaintiff since October 1, 2020. Plaintiff inserted numerous boilerplate objections and
failed to provide an adequate response. Please supplement with the requested information.
Interrogatory No. 2 Transocean requested Plaintiff to identify all accounts of any and all social
media platforms held by him from October 1, 2020 to the present. Instead of providing an adequate
response, Plaintiff again inserts boilerplate objections. Despite Plaintiff’s claim that this request violates
Plaintiff’s and his wife’s right to privacy, please be aware that the internet is a public forum that anyone
with an internet connection can access. Please supplement with the requested information.
We also request Plaintiff supplement each set of his discovery responses to date with any
additional information and documents that are currently in his possession, custody, and control. This
request includes any and all documents that Plaintiff has located since serving his responses.
Page
Please be advised that if Plaintiff does not timely supplement his deficient discovery, we will be
forced to seek court intervention. Plaintiff does not satisfy his outstanding discovery by Wednesday
February 2 Transocean will be ing a Motion to Compel with the Court
I look forward to your response and please do not hesitate to contact me if you have any questions.
Sincerely
EAN ILLER
Timothy W. Strickland
TWS:
Preview
Joseph Canida From: Tim Strickland Sent: Thursday, March 21, 2024 9:16 AM To: Roland Christensen; Caj Boatright; Kurt Arnold Cc: Shahmeer Halepota; Tod Everage; Laura Dumas; Joseph Canida Subject: Asgard- Glass Supplemental Production Attachments: Glass 2024.02.21 - MDL - 11-56 am-TWS to A&I re Glass Deficient Discovery.pdf Gents, See attached letter dated 21 February 2024 seeking supplemental discovery from Mr. Glass. We mentioned this briefly during the 1 March 2024 status conference with Judge Collier. We kindly request that Mr. Glass supplement his production. Do not hesitate to contact me if you have any questions. Tim Strickland Partner 713.844.3031 (direct) 281.380.0569 (mobile) TIMOTHY W. STRICKLAND, PARTNER PH 713.844.3031 TIM.STRICKLAND@KEANMILLER.COM February Via Service Roland Christensen rchristensen@arnolditkin.com Mr. Caj Boatwright cboatright@arnolditkin.com Mr. Kurt Arnold karnold@arnolditkin.com ARNOLD & ITKIN 6009 Memorial Drive Re: Hurricane Zeta Litigation MDL 113th Judicial District Court for Harris County, Texas Case No: 2022 Bradford Glass vs. Transocean Drilling (U.S.A.), Inc., et al. Judicial District Court for Harris County, Texas Case No.: 202 File No. Dear Counsel I am writing regarding multiple deficiencies identified in Plaintiff’s Discovery Responses to Transocean as identified below: Plaintiff’s Responses to Transocean’s First Set of Discovery Request for Production No. 21 & 22 Transocean requested that Plaintiff produce copies of all photographs, videotapes, or motion pictures of Plaintiff taken since the date of the incident relating to any aspect of this lawsuit, and any media that allegedly depict the incident or any damages claimed by Plaintiff. Plaintiff indicated in his response that he would supplement all responsive media in his possession, but Transocean still has not received any relevant responsive production to date Please supplement with all responsive photographs and motion pictures in Plaintiff’s possession. Further, as you recall from the deposition of Eliana Glass, Plaintiff’s spouse, on February 13, 2024, she testified that the Glass’ have gone on multiple trips and family vacations since the date of the incident, serving as chaperones for their daughter, Jordan G senior trip to the Dominican Republic on or around Spring 2023. Include in your supplemental production photographs and motion pictures taken of Plaintiff during the family’s travels as Ms. Glass testified to in her deposition, as it relates to Page Plaintiff alleged damages regarding his quality of life and enjoyment of leisure activities since the date of the alleged incident. Requests for Production Nos. 27, 58, Transocean also requested the production of all posts and photographs posted to any Facebook, Instagram, or Twitter account om October 1, 2020 through the present, along with account data from October 1, 2020 through the present for any Facebook account maintained by Plaintiff. Plaintiff did not provide an adequate response, merely inserting blanket objections to each request. Please produce the requested documents and information. Request for Production No. Pertaining to any item of cure Plaintiff contends Transocean has failed to pay, Transocean requested Plaintiff to produce documents substantiating that Transocean received notice that cure was owed for each such item Plaintiff stated he will produce all billing records, which is not with this request is seeking. Please supplement with the requested documents or amend the response accordingly. Requests for Production No. 65 & Plaintiff objected to Transocean’s request f any written or recorded statement of aintiff or any representative f Plaintiff, along with any Transocean agent, employee, or representative in Plaintiff’s possession, stating th are duplicative request when y are in fact not. Please supplement with any and all responsive documents and correspondence in Plaintiff’s possession, custody, or control. Request for Production No. 99 Plaintiff stated he produced all responsive documents in his possession. However, Eliana Glass testified in her deposition that she owns and operates a Pump It Up franchise party event center in Brandon, Mississippi Ms. Glass further testified that the legal name of the business is G&A Entertainment, LLC. Filings obtained from the Mississippi Secretary of State for G&A Entertainment, LLC indicate that Plaintiff has been manager of the business since its formation in , while Ms. Glass has been acting as a Managing Member. Therefore, please produce all responsive federal and state business tax filings for G&A entertainment, LLC, as it pertains to a business interest owned by Plaintiff. Plaintiff’s Responses to Transocean’s Second Set of Discovery nterrogatory No. 1 Transocean requested all cell phone numbers and corresponding service providers used by Plaintiff since October 1, 2020. Plaintiff inserted numerous boilerplate objections and failed to provide an adequate response. Please supplement with the requested information. Interrogatory No. 2 Transocean requested Plaintiff to identify all accounts of any and all social media platforms held by him from October 1, 2020 to the present. Instead of providing an adequate response, Plaintiff again inserts boilerplate objections. Despite Plaintiff’s claim that this request violates Plaintiff’s and his wife’s right to privacy, please be aware that the internet is a public forum that anyone with an internet connection can access. Please supplement with the requested information. We also request Plaintiff supplement each set of his discovery responses to date with any additional information and documents that are currently in his possession, custody, and control. This request includes any and all documents that Plaintiff has located since serving his responses. Page Please be advised that if Plaintiff does not timely supplement his deficient discovery, we will be forced to seek court intervention. Plaintiff does not satisfy his outstanding discovery by Wednesday February 2 Transocean will be ing a Motion to Compel with the Court I look forward to your response and please do not hesitate to contact me if you have any questions. Sincerely EAN ILLER Timothy W. Strickland TWS: