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`Exhibit 1
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`Case 5:21-cv-04653-BLF Document 123-2 Filed 05/03/22 Page 2 of 2
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`From:
`Sent:
`To:
`Cc:
`Subject:
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`[EXTERNAL EMAIL]
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`Good morning Madam Clerk,
`
`Minna Chan <mchan@raklaw.com>
`Monday, May 2, 2022 9:56 AM
`SvKCRD@cand.uscourts.gov
`AGIS; agis@raklaw.com; Taylor, Jeremy; Salpietra, Bethany; DL Lyft AGIS
`5:21-cv-04653-BLF | Lyft, Inc. v. AGIS Software Development LLC
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`AGIS Software respectfully submits that, to resolve the dispute regarding P.L.R. 3-2, AGIS Software will produce the EDTX
`P.R. 3-2 production as requested by Lyft in its briefing and during Friday’s hearing. For background, the parties discussed
`two parts to Lyft’s request for P.L.R. 3-2. First, AGIS Software agreed to produce all settlement agreements on a rolling
`basis after notice clearances. Second, Lyft’s briefing submitted that P.L.R. 3-2(a)-(c) is coextensive with EDTX P.R. 3-2
`and that AGIS Software should produce the same 3-2 documents in this case notwithstanding that they are AGIS, Inc.
`documents. Dkt. 88 at 2-3. The Court made clear during the hearing that it viewed the prior litigation productions
`under 3-2 as separate and unique from the issue of whether AGIS Software generally has possession, custody, and
`control over AGIS, Inc. documents, which it does not. In an effort to resolve the outstanding dispute regarding the prior
`EDTX P.R. 3-2 production, AGIS Software has informed Lyft that it will produce the entirety of the EDTX P.R. 3-2
`production, including the AGIS, Inc. documents which were produced in EDTX under voluntary cooperation prior to
`issuance of a subpoena. Accordingly, AGIS believes that this resolution moots the dispute and obviates the need for the
`supplemental briefing due today at noon. AGIS expect to make the production to Lyft within the next couple of hours.
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`We have also copied Lyft’s counsel to this email thread.
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`Regards,
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`Minna Chan
`Russ, August & Kabat
`12424 Wilshire Boulevard, 12th Floor | Los Angeles, CA 90025
`Main +1 (310) 826-7474 | Direct +1 (310) 979-8254
`mchan@raklaw.com
`-----------------------------------
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