`Case 1:20-cv-00393-LO-TCB Document 616-2 Filed 05/14/21 Page 1 of 3 Page|D# 14009
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`EXHIBIT 2
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`EXHIBIT 2
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`Case 1:20-cv-00393-LO-TCB Document 616-2 Filed 05/14/21 Page 2 of 3 PageID# 14010
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`From:
`Sent:
`To:
`Cc:
`Subject:
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`Smith, Nicole M. <nmsmith@jonesday.com>
`Friday, May 14, 2021 1:50 PM
`Koh, Jennifer (SD)
`#C-M PMIEDVA - LW TEAM; RJREDVA
`RE: Kodama deposition
`
`Hi Jennifer,
`
`I did indeed miss your voicemail. Mr. Kodama has already moved around his schedule to accommodate
`Monday’s deposition. We confirmed Mr. Kodama’s availability for May 10 a full month ago, on April 13. Mr.
`Kodama kept May 10 open only to have it canceled at the last minute, and pushed another full week to May
`17. Defendants need to proceed with this long-scheduled deposition on Monday; they have had ample time
`to prepare and accommodate the unavailability of one of their own attorneys. Mr. Kodama will appear on
`Monday. If you choose not to take his deposition, we will not be making him available again.
`
`-Nicole
`
`Nicole Smith (bio)
`Partner
`JONES DAY® - One Firm Worldwide℠
`555 S. Flower St., 50th Floor
`Los Angeles, CA 90071
`Office 213-243-2235
`Cell 310-497-5046
`
`From: Jennifer.Koh@lw.com <Jennifer.Koh@lw.com>
`Sent: Friday, May 14, 2021 9:10 AM
`To: Smith, Nicole M. <nmsmith@jonesday.com>
`Subject: Kodama deposition
`
`** External mail **
`
`Hi Nicole,
`
`Good morning, just wanted to follow up on my voice mail to you yesterday (in the event you didn’t
`receive it). We understand Mr. Kodama is not available any other days the week of the 17th and were
`wondering if he was available for deposition the week of the 24th. I understand you might not have an
`alternate date from him yet but just wanted to make sure that we can agree that the deposition will not
`go forward on the 17th. Thanks again for your and Mr. Kodama’s understanding and flexibility here.
`I’m at 858-523-3949 if needed.
`
`Thanks,
`Jennifer
`
`
`Jennifer Koh
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`1
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`Case 1:20-cv-00393-LO-TCB Document 616-2 Filed 05/14/21 Page 3 of 3 PageID# 14011
`LATHAM & WATKINS LLP
`12670 High Bluff Drive
`San Diego, CA 92130
`Direct Dial: +1.858.523.3949
`Email: jennifer.koh@lw.com
`https://www.lw.com
`
`
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