Wilbert Smith Archives Files Box 1136 23 1136-23-p006

Document Text (OCR)

cS mentioned above Two crucial differences from the two are first, that in this case a novo scarch was performed und, second that the de novo search was based on a Stipulation. The issue of the & thoroughness of the defendant's search has been “simplified” by the Stipulation, which specifically addressed both the “description of the + documents requested” and the requirements of a “reasonable search.” The | second and third pages of the Stipulation éctail what major, publicly ; known components...