After vetting these documents to insure that they were not privileged and complied with only what we agreed to provide, we produced the responsive documents to ENH’s counsel.
Although this initial production did not fully comply with the agreed upon scope of the subpoena, we are hopeful that the production will satisfy ENH and that it will release us from the subpoena without expending any additional resources. In this regard, we recently spoke with ENH’s counsel and advised Universal American/APS provided everything that APS has after expending a significant amount of time and manpower identifying and collecting the documents. ENH’s counsel indicated that he would discuss APS’ production with his team, and will advise whether ENH will require any additional documents.
VI.