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Scott. Court and counsel confer. The IDC is continued to 4/3/2026 at 9:30 am. Counsel shall notify the clerk if the the dispute is resolved in the meantime. APPEARANCES: Jeremy Robinson and Thomas Sperber for Movant(s); Kristin Murphy, Jordan Cook, and Jordan Mundell for Defendant(s). Deputy Clerk: Jazmin Dorado. Time in cour :17. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. Court Recorder: CourtSmart. 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Fleming APPLICATION to Appear Pro Hac Vice on behalf of Movants City of Fort Lauderdale Police & Firefighters Retirement System, Louisiana Sheriffs' Pension & Relief Fund, designating Jonathan D. Uslaner as local counsel. 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ROBINSON (pro hac vice)\n 3 1251 Avenue of the Americas\n 4 New York, NY 10020\n Telephone: (212) 554-1400\n 5 jeremy@blbglaw.com\n 6 Tel: (310) 819-3481\n\n 7 Lead Counsel for Lead Plaintiffs\n 8 Louisiana Sheriffs\u2019 Pension & Relief Fund and\n City of Fort Lauderdale Police & Firefighters\u2019\n 9 Retirement System and the Settlement Class\n10\n11\n12 UNITED STATES DISTRICT COURT\n13 CENTRAL DISTRICT OF CALIFORNIA\n SOUTHERN DIVISION\n14\n15 DHIMANT PATEL, Individually and on Case No. 8:24-cv-02221-AH-KES\n16 Behalf of All Others Similarly Situated,\n LEAD PLAINTIFFS\u2019 LETTER TO\n17 Plaintiff, THE COURT ENCLOSING\n18 REVISED PROPOSED\n v. PRELIMINARY APPROVAL\n19 ORDER WITH REVISED\n20 EDWARDS LIFESCIENCES SCHEDULE\n CORPORATION and BERNARD J.\n21 ZOVIGHIAN, Judge: Hon. Anne Hwang\n22 Courtroom: 9C, 9th Floor\n Defendants.\n23\n24\n25\n26\n27\n28\n LEAD PLAINTIFFS\u2019 LETTER TO THE COURT\n CASE NO. 8:24-cv-02221-AH-KES\n\fCase 8:24-cv-02221-AH-KES Document 102 Filed 07/30/26 Page 2 of 3 Page ID\n #:1376\n B E R NS T EI N LIT O WI T Z BE R GE R & G ROSS MA N N L LP\n ATTORNEYS AT LAW\n NEW YORK \u25cf CALIFORNIA \u25cf ILLINOIS \u25cf LOUISIANA \u25cf DELAWARE\n\nJEREMY P. ROBINSON\n(212) 554-1492\nJeremy@blbglaw.com\n\n\n July 30, 2026\n\nVia ECF\n\nThe Honorable Anne Hwang\nFelicitas and Gonzalo Mendez United States Courthouse\n350 W. 1st Street\nLos Angeles, CA 90012\n\n Re: Patel v. Edwards Lifesciences Corp., Case No. 8:24-cv-02221-AH-KES\n (C.D. Cal.)\n\nDear Judge Hwang:\n\n We represent Lead Plaintiffs in the above-referenced class action. Further to yesterday\u2019s\nhearing, attached as Exhibit 1 is a revised version of the Parties\u2019 [Proposed] Order Preliminarily\nApproving Settlement and Providing for Notice of Settlement (\u201cPreliminary Approval Order\u201d).\n\n As discussed at the hearing, the revised Preliminary Approval Order accommodates a\nClaims-filing deadline prior to the final approval hearing as well as a final approval hearing\nscheduled for this year. A full schedule of the applicable calendar dates, assuming that the\nPreliminary Approval Order is entered on Friday, July 31, 2026, and that the Court schedules the\nfinal approval hearing for Wednesday, December 16, 2026, follows:\n\nEVENT DEADLINE CALENDAR DATE\n\nDeadline to commence mailing 15 business days after Friday, August 21, 2026\nthe Notice and Claim Form entry of the Preliminary\nto Settlement Class Members Approval Order\n(\u201cNotice Date\u201d)\n\nDeadline for publishing the 10 business days after the Friday, September 4, 2026\nSummary Notice Notice Date\n\nDeadline for submitting Claim 100 calendar days after Monday, November 30, 2026\nForms the Notice Date\n\nDeadline for requesting exclusion 100 calendar days after Monday, November 30, 2026\nfrom the Settlement Class or filing the Notice Date\nan objection to the Settlement\n\n\n\n1251 AVENUE OF THE AMERICAS \u25cf NEW YORK \u25cf NY 10020-1104\nTELEPHONE: 212-554-1400 \u25cf www.blbglaw.com \u25cf FACSIMILE: 212-554-1444\n\f Case 8:24-cv-02221-AH-KES\n Document 102 Filed 07/30/26 Page 3 of 3 Page ID\n #:1377 LLP\nBERNSTEIN LITOWITZ BERGER & GROSSMANN\n\nHon. Anne Hwang\nJuly 30, 2026\nPage 2\n\n Deadline for filing papers in 35 calendar days before Wednesday, November 11,\n support of final settlement the date scheduled for the 2026\n approval, the Plan of Allocation, Settlement Hearing\n and the request for attorneys\u2019 fees\n and Litigation Expenses\n\n Deadline for filing reply papers 7 calendar days before Wednesday, December 9, 2026\n the date scheduled for the\n Settlement Hearing\n\n Settlement Hearing Wednesday, December 16,\n 2026, at 1:30 p.m.\n\n\n\n The Parties have conferred and Defendants do not oppose the proposed schedule and\n respectfully defer to the Court\u2019s preference.\n\n We thank the Court for its attention to this matter.\n\n Respectfully submitted,\n\n /s/ Jeremy P. Robinson\n Jeremy P. Robinson\n\n Lead Counsel for Lead Plaintiffs City of Fort\n Lauderdale Police & Firefighters\u2019 Retirement\n System and Louisiana Sheriffs\u2019 Pension &\n Relief Fund\n\n\n cc: All counsel of record (via ECF)\n\f","ocr_status":1,"date_upload":"2026-10-19T06:25:16.204562-07:00","document_number":"102","attachment_number":null,"pacer_doc_id":"031048468743","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Miscellaneous Document","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/497686792/","id":497686792,"tags":[],"absolute_url":"/docket/69258750/102/1/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-10-19T06:25:13.862096-07:00","date_modified":"2026-10-19T06:25:13.862128-07:00","sha1":"","page_count":17,"file_size":156774,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"102","attachment_number":1,"pacer_doc_id":"031048468744","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Proposed Order","acms_document_guid":""}],"date_created":"2026-07-30T16:03:30.765708-07:00","date_modified":"2026-10-03T05:48:28.339011-07:00","date_filed":"2026-07-30","time_filed":"15:30:06","entry_number":102,"recap_sequence_number":"2026-07-30.001","pacer_sequence_number":332,"description":"Letter filed by Movants City of Fort Lauderdale Police & Firefighters Retirement System, Louisiana Sheriffs' Pension & Relief Fund (Attachments: # 1 Proposed Order)(Robinson, Jeremy) (Entered: 07/30/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472738751/","id":472738751,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488182011/","id":488182011,"tags":[],"absolute_url":"","date_created":"2026-07-30T15:05:23.632788-07:00","date_modified":"2026-07-30T15:05:23.632801-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Motion Hearing","acms_document_guid":""}],"date_created":"2026-07-30T15:05:23.621459-07:00","date_modified":"2026-07-30T15:05:23.621475-07:00","date_filed":"2026-07-30","time_filed":"14:47:11","entry_number":null,"recap_sequence_number":"2026-07-30.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/469508240/","id":469508240,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/484848461/","id":484848461,"tags":[],"absolute_url":"/docket/69258750/100/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-07-01T19:34:31.395797-07:00","date_modified":"2026-07-01T19:34:31.405267-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"100","attachment_number":null,"pacer_doc_id":"031048196929","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-07-01T19:34:31.370339-07:00","date_modified":"2026-10-03T05:48:28.272088-07:00","date_filed":"2026-07-01","time_filed":"19:23:31","entry_number":100,"recap_sequence_number":"2026-07-01.001","pacer_sequence_number":328,"description":"NOTICE OF MOTION AND MOTION for Order for Preliminary Approval of Proposed Settlement filed by Lead Plaintiffs City of Fort Lauderdale Police & Firefighters Retirement System, Louisiana Sheriffs' Pension & Relief Fund. Motion set for hearing on 7/29/2026 at 01:30 PM before Judge Anne Hwang. (Attachments: # 1 Exhibit 1 - Stipulation and Agreement of Settlement, # 2 Exhibit 2 - Proposed Order Preliminarily Approving Settlement and Providing for Notice of Settlement) (Robinson, Jeremy) (Entered: 07/01/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/460021011/","id":460021011,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/475066668/","id":475066668,"tags":[],"absolute_url":"","date_created":"2026-04-07T17:03:54.266563-07:00","date_modified":"2026-04-07T17:03:54.273068-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"For Order","acms_document_guid":""}],"date_created":"2026-04-07T17:03:54.248018-07:00","date_modified":"2026-04-07T17:03:54.248030-07:00","date_filed":"2026-04-07","time_filed":"16:46:44","entry_number":null,"recap_sequence_number":"2026-04-07.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459616178/","id":459616178,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474647535/","id":474647535,"tags":[],"absolute_url":"/docket/69258750/97/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-04-03T08:32:53.966611-07:00","date_modified":"2026-04-03T08:32:53.973956-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"97","attachment_number":null,"pacer_doc_id":"031047412095","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"-Transcript","acms_document_guid":""}],"date_created":"2026-04-03T08:32:53.944429-07:00","date_modified":"2026-10-03T05:48:28.156770-07:00","date_filed":"2026-04-03","time_filed":"08:08:41","entry_number":97,"recap_sequence_number":"2026-04-03.001","pacer_sequence_number":321,"description":"TRANSCRIPT for proceedings held on 04/01/2026 at 9:32 AM. Court Reporter/Electronic Court Recorder: EXCEPTIONAL REPORTING SERVICES, INC., phone number (361) 949-2988. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Electronic Court Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Notice of Intent to Redact due within 7 days of this date. Redaction Request due 4/24/2026. Redacted Transcript Deadline set for 5/4/2026. Release of Transcript Restriction set for 7/2/2026. (cr) (Entered: 04/03/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459616176/","id":459616176,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474647533/","id":474647533,"tags":[],"absolute_url":"","date_created":"2026-04-03T08:32:53.733923-07:00","date_modified":"2026-04-03T08:32:53.740136-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice of Filing Transcript","acms_document_guid":""}],"date_created":"2026-04-03T08:32:53.720781-07:00","date_modified":"2026-04-03T08:32:53.720795-07:00","date_filed":"2026-04-03","time_filed":"08:11:00","entry_number":null,"recap_sequence_number":"2026-04-03.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459557867/","id":459557867,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474587696/","id":474587696,"tags":[],"absolute_url":"","date_created":"2026-04-02T15:36:21.267398-07:00","date_modified":"2026-04-02T15:36:21.275087-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Text Only Scheduling Notice","acms_document_guid":""}],"date_created":"2026-04-02T15:36:21.253101-07:00","date_modified":"2026-04-02T15:36:21.253113-07:00","date_filed":"2026-04-02","time_filed":"15:05:51","entry_number":null,"recap_sequence_number":"2026-04-02.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459541317/","id":459541317,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474570949/","id":474570949,"tags":[],"absolute_url":"/docket/69258750/95/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-04-02T14:04:12.109744-07:00","date_modified":"2026-04-02T14:04:12.114785-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"95","attachment_number":null,"pacer_doc_id":"031047405294","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"-Transcript Order Form (G-120)","acms_document_guid":""}],"date_created":"2026-04-02T14:04:12.090184-07:00","date_modified":"2026-10-03T05:48:28.097689-07:00","date_filed":"2026-04-02","time_filed":"13:55:20","entry_number":95,"recap_sequence_number":"2026-04-02.002","pacer_sequence_number":316,"description":"TRANSCRIPT ORDER as to Defendants Edwards Lifesciences Corporation, Bernard J. Zovighian for Court Smart (CS). Court will contact Jaime Garcia at jaime.garcia@lw.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the transcription company. (Cook, Jordan) (Entered: 04/02/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459528650/","id":459528650,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474558027/","id":474558027,"tags":[],"absolute_url":"/docket/69258750/94/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-04-02T13:02:42.546675-07:00","date_modified":"2026-04-02T13:02:42.552138-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"94","attachment_number":null,"pacer_doc_id":"031047404003","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"-Transcript Order Form (G-120)","acms_document_guid":""}],"date_created":"2026-04-02T13:02:42.526671-07:00","date_modified":"2026-10-03T05:48:28.080346-07:00","date_filed":"2026-04-02","time_filed":"12:49:13","entry_number":94,"recap_sequence_number":"2026-04-02.001","pacer_sequence_number":314,"description":"TRANSCRIPT ORDER as to Lead Plaintiffs City of Fort Lauderdale Police & Firefighters Retirement System, Louisiana Sheriffs' Pension & Relief Fund for Court Smart (CS). Court will contact Christopher Hilton at Christopher.Hilton@blbglaw.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the transcription company. (Sperber, Thomas) (Entered: 04/02/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459410662/","id":459410662,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474436819/","id":474436819,"tags":[],"absolute_url":"","date_created":"2026-04-01T16:02:58.915228-07:00","date_modified":"2026-04-01T16:02:58.922334-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Discovery Hearing AND ~Util - Set/Reset Hearings","acms_document_guid":""}],"date_created":"2026-04-01T16:02:58.898000-07:00","date_modified":"2026-04-01T16:02:58.898020-07:00","date_filed":"2026-04-01","time_filed":"15:42:41","entry_number":null,"recap_sequence_number":"2026-04-01.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459152900/","id":459152900,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474172126/","id":474172126,"tags":[],"absolute_url":"/docket/69258750/91/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-03-31T09:37:11.542849-07:00","date_modified":"2026-05-22T03:08:59.288186-07:00","sha1":"43645ea9f77bb0ad6e16e387fe40a93733d44960","page_count":5,"file_size":311622,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:24-cv-02221-AH-KES Document 91 Filed 03/31/26 Page 1 of 5 Page ID\n #:1068\n\n\n 1 BERNSTEIN LITOWITZ BERGER\n & GROSSMANN LLP\n 2 JONATHAN D. USLANER (Bar No. 256898)\n jonathanu@blbglaw.com\n 3 2121 Avenue of the Stars, Suite 2575\n Los Angeles, CA 90067\n 4 Tel: (310) 819-3470\n 5 Counsel for Lead Plaintiffs\n Louisiana Sheriffs\u2019 Pension & Relief Fund and\n 6 City of Fort Lauderdale Police & Firefighters\u2019\n Retirement System\n 7\n [Additional counsel appear on signature page.]\n 8\n 9\n UNITED STATES DISTRICT COURT\n10 CENTRAL DISTRICT OF CALIFORNIA\n11\n DHIMANT PATEL, Individually and on Case No. 8:24-cv-02221-AH-KES\n12 behalf of itself and all others similarly\n situated, Discovery Document: Referred to\n13 Magistrate Judge Karen E. Scott\n Plaintiff,\n14\n v.\n15 PLAINTIFFS\u2019 LETTER BRIEF RE:\n EDWARDS LIFESCIENCES APRIL 1, 2026 INFORMAL\n16 CORPORATION, BERNARD J. TELEPHONIC CONFERENCE\n ZOVIGHIAN.\n17\n Defendants. Date: April 1, 2026\n18 Time: 9:30 a.m.\n Judge: Hon. Karen E. Scott\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n PLAINTIFFS\u2019 LETTER BRIEF RE INFORMAL TELEPHONIC CONFERENCE\n CASE NO. 8:24-CV-02221-AH-KES\n\fCase 8:24-cv-02221-AH-KES Document 91 Filed 03/31/26 Page 2 of 5 Page ID\n #:1069\n\nHon. Karen E. Scott\nUnited States Magistrate Judge,\nU.S. District Court, Central District of California\n\nDear Judge Scott:\n Plaintiffs respectfully submit this letter brief in support of their motion to compel\nDefendants to produce documents for the period from January 1 to November 30, 2023 (the\n\u201cDisputed Period\u201d).1\n This securities class action arises from Defendants\u2019 misleading statements to investors\nabout the growth prospects of Edwards Lifesciences Corporation\u2019s (\u201cEdwards\u201d or the \u201cCompany\u201d)\nflagship product, Transcatheter Aortic Valve Replacement (\u201cTAVR\u201d) heart valves. Plaintiffs\u2019\nComplaint (ECF No. 52) alleges that Defendants repeatedly told investors to expect 8-10% growth\nin TAVR sales for 2024 while they dismissed concerns that hospital capacity constraints presented\na challenge to that growth. In truth, Defendants knew that TAVR growth had slowed and that\nlimited hospital capacity to perform TAVR procedures was a challenge to their projected growth.\n Defendants developed the allegedly misleading 8-10% growth projections in 2023.\nDefendants also learned facts in early 2023 that undermined or were contrary to their growth\nprojections, which the Court expressly relied on in sustaining Plaintiffs\u2019 Complaint in its motion\nto dismiss opinion (the \u201cOpinion\u201d). ECF No. 72. Despite this reality, Defendants refuse to produce\ndocuments from prior to December 1, 2023, cutting off many months of relevant documents. They\nshould be required to produce responsive documents dating from the Disputed Period.\nI. RELEVANT BACKGROUND\n\nA. The Parties Met and Conferred Extensively Regarding This Dispute\n\n The Parties engaged in an extensive meet and confer process regarding this dispute. To\nbegin, Plaintiffs\u2019 First Set of Requests for Production (the \u201cRFPs\u201d) sought the production of\nresponsive documents for the period from January 1, 2023 to February 28, 2025 (the \u201cRelevant\nTime Period\u201d). Ex. 1.2 In their responses (the \u201cRFP Responses\u201d), Defendants objected to the\nRelevant Time Period and sought to limit their production to December 1, 2023 through August\n31, 2024. Ex. 2.\n Plaintiffs accepted Defendants\u2019 proposed end-date of August 31, 2024. However, Plaintiffs\nexplained that documents dating from Disputed Period are highly relevant, including because the\nComplaint includes multiple allegations about events in early 2023. E.g., ECF No. 52 \u00b6\u00b662-66, 80-\n83. Moreover, as Plaintiffs also explained, the Court expressly relied on facts dating from within\nthe Disputed Period in sustaining Plaintiffs\u2019 claims. ECF No. 72 at 16-17 and n.7. Plaintiffs further\n\n\n\n1 The parties also had a ripe dispute over whether Defendants would produce documents from\nthe custodial files of Donald Bobo, Corporate V.P., Strategy and Corporate Development at\nEdwards. After Plaintiffs filed the Notice (ECF No. 88), Defendants agreed to produce Mr.\nBobo\u2019s responsive documents. Accordingly, the Court need not address that dispute.\n2 Cites to \u201cEx.\u201d refer to the Exhibits hereto and cites to \u201c\u00b6_\u201d refer to paragraphs in the\nComplaint.\n\fCase 8:24-cv-02221-AH-KES Document 91 Filed 03/31/26 Page 3 of 5 Page ID\n #:1070\n\nexplained that they are entitled to discovery regarding the formation of the Company\u2019s 2024 sales\nguidance, which took place in 2023. Ex. 3 at 1. Defendants\u2019 position was that documents dating\nfrom the Disputed Period are irrelevant. Later, Defendants agreed to produce the \u201c2024 strategic\nplanning documents\u201d dating from 2023\u2014conceding the relevance of 2023 documents\u2014but\nmaintained their refusal to provide full productions from the Disputed Period. Ex. 4 at 3.\n The parties agreed that they are at an impasse and agreed to proceed by way of the Court\u2019s\ninformal discovery conference procedures.\nII. ARGUMENT\n\n Plaintiffs respectfully submit that the Court\u2019s Opinion and the Complaint\u2019s allegations\nestablish that documents from the Disputed Period are relevant and should be produced.\nDefendants, as \u201cthe part[ies] resisting discovery bear[] the burden of showing why discovery\nshould not be allowed.\u201d United States ex rel. Poehling v. UnitedHealth Grp., Inc., 2018 WL\n8459926, at *9 (C.D. Cal. Dec. 14, 2018). Defendants have not met their burden here.\n First, in its Opinion, the Court expressly credited factual allegations dating from 2023 in\nsustaining Plaintiffs\u2019 securities claims, including regarding Defendant Zovighian\u2019s knowledge and\nscienter. For example, the Court explained, citing allegations based on former Edwards employee\nFE-5\u2019s report, that \u201cin the Spring of 2023, a company-wide townhall took place where the decline\nin TAVR rates was discussed, and that she also raised the issue of the decline in TAVR rates with\nan individual who she understood discussed it with Defendant Zovighian.\u201d Opinion at 16. The\nCourt also explained, quoting allegations based on information supplied by FE-1, that \u201cEdwards\nexecutives knew there were problems with TAVR growth as early as 2023.\u201d Id.\n Thus, by refusing to produce documents for the Disputed Period, Defendants want to\nwithhold contemporaneous documents concerning the very facts that the Court relied on\u2014and\nfound to be relevant\u2014in its Opinion sustaining the Complaint. This would deprive Plaintiffs, as\nwell as the Court, of documents concerning the \u201cmisleadingly omitted facts [that Defendants\nallegedly] knew regarding stalled TAVR growth and the negative impact of hospital capacity\nconstraints.\u201d Opinion at 18 (quoting Plaintiffs\u2019 motion to dismiss opposition brief at 18).\n Second, other allegations in the Complaint further confirm the direct relevance of 2023\ndocuments. For example, in addition to the reports from FE-1 and FE-5 (discussed above), the\nComplaint includes allegations based on information supplied by FE-3, who reported documenting\na 20-40% decrease in TAVR volumes between Q4 2023 and Q1 2024. \u00b670. This allegation\nunderscores that documents dating from prior to December 1, 2023 are relevant and that\nDefendants\u2019 proposed limitation is insufficient. Even if Defendants agreed to produce documents\nfrom Q4 2023 (which Defense counsel vaguely suggested as a possibility during the meet and\nconfer process), that would still be insufficient. As explained above, events much earlier in 2023\nare indisputably relevant and expressly relied on by the Court in sustaining Plaintiff\u2019s claims.\n Third, courts in this Circuit routinely hold that pre-class period documents are\ndiscoverable. E.g., In re Dockers Roundtrip Airfare Promotion Sales Pracs. Litig., 2010 WL\n11515318, at *5 (C.D. Cal. Aug. 1, 2010) (\u201cIn general, courts allow discovery to extend to events\nbefore and after the period of actual liability so as to provide context.\u201d). Indeed, Courts have\ncompelled discovery predating the start of a relevant period for time ranges the same length as\u2014\nand even years longer than\u2014the Disputed Period at issue here. E.g., Ogden v. Bumble Bee Foods,\nLLC, 292 F.R.D. 620, 628 (N.D. Cal. 2013) (compelling discovery from four years pre-class\n 2\n\fCase 8:24-cv-02221-AH-KES Document 91 Filed 03/31/26 Page 4 of 5 Page ID\n #:1071\n\nperiod); Karinski v. Stamps.com, Inc., 2020 WL 5084093, at *2 (C.D. Cal. July 21, 2020)\n(compelling discovery from 15 months pre-class period).\n In securities fraud cases in particular, courts permit discovery extending before the class\nperiod to demonstrate falsity and scienter. E.g., In re Toyota Motor Corp. Sec. Litig., 2012 WL\n3791716, at *4 (C.D. Cal. Mar. 12, 2012) (\u201ccommon sense dictates that facts relevant to scienter\nwill ordinarily date from before any alleged misrepresentations because the circumstances\npreceding the statements would be among those knowable at the time of the statements.\u201d) (internal\ncitations omitted). This discovery is especially appropriate where, as here: (i) the Complaint\nspecifically alleges that Defendants had material knowledge before the Class Period (February 6,\n2024, to July 24, 2024), and (ii) Defendants\u2019 statements were based at least in part on pre-class\nperiod analyses and data. Id. at *5.\n Indeed, documents concerning the assumptions, inputs, and calculations that went into\nEdwards\u2019 8-10% TAVR sales guidance for 2024, and communications about them, all were created\nin 2023. Defendants conceded this reality by agreeing to produce the \u201cstrategic planning\ndocuments\u201d dating from 2023. But Defendants still intend to withhold the information and data\nthat went into the creation of those documents, including, for example, (i) TAVR procedure\nvolume data from throughout 2023; (ii) analysis of hospital capacity constraints and trends in 2023;\n(iii) assessments of competitive dynamics in the TAVR market in 2023; and (iv) documents and\ncommunications from 2023 concerning Edwards\u2019 strategic planning for 2024. Analyzing this\nmaterial and assessing how (if at all) it factored into Edwards\u2019 projections of 2024 TAVR sales\ngrowth will have direct bearing on whether Defendants knowingly omitted material information.\n Fourth, during the meet and confer process, Defendants asserted that documents\nconcerning the creation of the December 7, 2023 8-10% TAVR growth guidance are irrelevant\nbecause that specific statement itself was not alleged as an actionable misstatement. This argument\nfails because the Court sustained Class Period false statements that explicitly reiterated that\nguidance. E.g., \u00b6108 (\u201cDefendants specifically assured investors that they were \u2018confident in the\nsales guidance [they] provided at the December 2023 investor conference for all product\ngroups,\u2019 which included Defendants\u2019 projection of 8%-10% growth for Edwards\u2019 TAVR segment\nin 2024.\u201d); \u00b6111 (\u201cDefendants also stated that they \u2018remain[ed] confident in TAVR sales growth\nof 8 to 10% on a constant currency basis\u2019. . . .\u201d); \u00b6112 (\u201cWe remain confident in our full year\nTAVR sales growth of 8% to 10%.\u201d). Thus, the basis for Defendants\u2019 TAVR growth guidance is\ndirectly at issue, as are communications about that guidance. Moreover, documents concerning\nwhat Defendants knew about TAVR sales when they created the guidance in 2023 have direct\nbearing on falsity, knowledge, and scienter. Indeed, it is this information that was allegedly omitted\nby Defendants, as the Court recognized in sustaining the Complaint. Opinion at 18.\n Fifth, given the relevance of documents dating from the Disputed Period, \u201cit is not\ndisproportionate to require their production.\u201d Markson v. CRST Int'l, Inc., 2021 WL 4027499, at\n*10 (C.D. Cal. May 14, 2021). During the meet and confer process, Defendants did not provide\nhit reports or metrics regarding the Disputed Period to support a claim of undue burden. Thus,\nDefendants\u2019 boilerplate and unsupported objection to the Relevant Time Period in their RFP\nResponses is improper and should not be credited. Duran v. Cisco Sys., Inc., 258 F.R.D. 375, 379\n(C.D. Cal. 2009) (\u201c[S]uch unexplained and unsupported boilerplate objections are improper.\u201d).\n Plaintiffs respectfully request that Defendants be required to search for and produce\nresponsive documents for the period from January 1 to November 30, 2023.\n 3\n\fCase 8:24-cv-02221-AH-KES Document 91 Filed 03/31/26 Page 5 of 5 Page ID\n #:1072\n\n\nDated: March 31, 2026 Respectfully submitted,\n\n BERNSTEIN LITOWITZ BERGER\n & GROSSMANN LLP\n\n /s/ Jeremy P. Robinson\n Salvatore J. Graziano (pro hac vice)\n Jeremy P. Robinson (pro hac vice)\n Timothy G. Fleming (pro hac vice)\n Thomas Z. Sperber (pro hac vice)\n Rebecca S. Temkin (pro hac vice)\n New York, NY 10020\n Tel: (212) 554-1400\n Fax: (212) 554-1444\n jeremy@blbglaw.com\n salvatore@blbglaw.com\n timothy.fleming@blbglaw.com\n thomas.sperber@blbglaw.com\n rebecca.temkin@blbglaw.com\n\n -and-\n\n Jonathan D. Uslaner (Bar No. 256898)\n (jonathanu@blbglaw.com)\n 2121 Avenue of the Stars, Suite 2575\n Los Angeles, CA 90067\n Tel: (310) 819-3481\n\n Counsel for Lead Plaintiffs, the Louisiana\n Sheriffs\u2019 Pension & Relief Fund and the City of\n Fort Lauderdale Police & Firefighters\n Retirement System\n\n\n\n\n 4\n\f","ocr_status":2,"date_upload":"2026-05-19T22:25:33.227809-07:00","document_number":"91","attachment_number":null,"pacer_doc_id":"031047376924","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Supplement (Motion related)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479806722/","id":479806722,"tags":[],"absolute_url":"/docket/69258750/91/1/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-05-19T22:25:33.620293-07:00","date_modified":"2026-05-22T08:37:30.462659-07:00","sha1":"6f376fbeb61108666607f441229a38da02a8d0fa","page_count":15,"file_size":177854,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 1 of 15 Page ID\n #:1073\n\n\n\n\n EXHIBIT 1\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 2 of 15 Page ID\n #:1074\n\n\n 1 BERNSTEIN LITOWITZ BERGER\n & GROSSMANN LLP\n 2 JONATHAN D. USLANER (Bar No. 256898)\n jonathanu@blbglaw.com\n 3 2121 Avenue of the Stars, Suite 2575\n Los Angeles, CA 90067\n 4 Tel: (310) 819-3470\n 5 Counsel for Lead Plaintiffs\n Louisiana Sheriffs\u2019 Pension & Relief Fund and\n 6 City of Fort Lauderdale Police & Firefighters\u2019\n Retirement System\n 7\n [Additional counsel appear on signature page.]\n 8\n\n 9\n UNITED STATES DISTRICT COURT\n10\n10 CENTRAL DISTRICT OF CALIFORNIA\n11\n11\n DHIMANT PATEL, Individually and on Case No. 8:24-cv-02221-AH-KES\n12\n12 behalf of itself and all others similarly\n13\n13 situated, PLAINTIFFS\u2019 FIRST SET OF\n REQUESTS FOR PRODUCTION\n14\n14 Plaintiff, OF DOCUMENTS DIRECTED TO\n15\n15 DEFENDANTS\n v.\n16\n16\n17\n17 EDWARDS LIFESCIENCES Judge: Hon. Anne Hwang\n CORPORATION, BERNARD J. Courtroom: 9C\n18\n18\n ZOVIGHIAN.\n19\n19\n20\n Defendants.\n20\n21\n21\n22\n22\n23\n23\n24\n24\n25\n25\n26\n26\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 1\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 3 of 15 Page ID\n #:1075\n\n\n 1 Lead Plaintiffs Louisiana Sheriffs\u2019 Pension & Relief Fund and City of Fort\n 2 Lauderdale Police & Firefighters\u2019 Retirement System, by and through their\n 3 undersigned counsel, hereby propound Plaintiffs\u2019 First Set of Requests for the\n 4 Production of Documents Directed to Defendants Edwards Lifesciences Corp.\n 5 (\u201cEdwards\u201d) and Bernard Zovghian (\u201cZovighian\u201d) (together with Edwards, the\n 6 \u201cDefendants\u201d), in accordance with Rules 26 and 34 of the Federal Rules of Civil\n 7 Procedure and the Local Rules of this Court. Plaintiffs request that Defendants\n 8 produce the documents described below for inspection and copying to the offices of\n 9 Bernstein Litowitz Berger & Grossmann LLP, 12481 High Bluff Drive, Suite 300,\n10\n10 San Diego, California 92130 within the time period mandated by the Rules, or at\n11\n11 such other time and place as the parties mutually agree. The documents requested\n12\n12 are to be produced according to the Definitions and Instructions described below.\n13\n13 Plaintiffs reserve the right to amend and/or supplement the Document Requests.\n14\n14 DEFINITIONS\n15\n15 1. \u201cAll\u201d means any and all.\n16\n16 2. \u201cCommunication\u201d means any recording or rendering of any contact,\n17\n17 oral or documentary, formal or informal, at any place or under any circumstance\n18\n18 whatsoever, whereby information of any nature is transmitted or transferred,\n19\n19 including a single person seeing or hearing any information by any means. The term\n20\n20 \u201cCommunication\u201d also includes drafts, revisions, or copies of any such\n21\n21 Communication if the draft, revision, or copy is in any way different from the\n22\n22 original.\n23\n23 3. The \u201cCompany\u201d or \u201cEdwards\u201d means Edwards Lifesciences\n24\n24 Corporation and includes all of its present and former divisions, subsidiaries,\n25\n25 affiliates, predecessors, successors, agents, representatives, and its present and\n26\n26 former officers, directors, and employees.\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 2\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 4 of 15 Page ID\n #:1076\n\n\n 1 4. \u201cComplaint\u201d means the Amended Consolidated Complaint For\n 2 Violations Of The Federal Securities Laws filed on March 21, 2025 in the above-\n 3 captioned action, see ECF No. 52.\n 4 5. \u201cConcerning\u201d means commenting on, comprising, constituting,\n 5 containing, describing, effecting, embodying, evidencing, identifying, including,\n 6 incorporating, involving, mentioning, referring to, reflecting, regarding, relating to,\n 7 responding to, stating, or in any way pertaining to, either directly or indirectly.\n 8 6. \u201cDefendants\u201d means Edwards Lifesciences Corporation and Bernard J.\n 9 Zovighian.\n10\n10 7. \u201cDocument\u201d or \u201cDocuments\u201d shall have the same meaning and be equal\n11\n11 in scope to the usage of the term \u201cdocuments or electronically stored information\u201d\n12\n12 in Federal Rule of Civil Procedure 34(a)(1)(A). For the avoidance of any doubt,\n13\n13 Documents includes Communications. A draft or non-identical copy is a separate\n14\n14 Document within the meaning of this term.\n15\n15 8. \u201cDocument Request\u201d means each of the specific document requests set\n16\n16 forth herein.\n17\n17 9. \u201cElectronically stored information\u201d or \u201cESI\u201d has the same meaning and\n18\n18 is equal in scope to the usage of the term in the Sedona Conference Definitions\n19\n19 (defined below), and includes, without limitation, the following:\n20\n20 (a) All items covered by Federal Rule of Civil Procedure\n21\n21 34(a)(1)(A);\n22\n22 (b) Information or data that is generated, received, processed, and\n23\n23 recorded by computers or other electronic devices, including Metadata;\n24\n24 (c) Internal or external websites;\n25\n25 (d) Output resulting from the use of any software program,\n26\n26 including but not limited to, any word-processing Documents, spreadsheets,\n27\n27 database files, charts, graphs, outlines, electronic mail, AOL or Bloomberg Instant\n28\n28 Messenger (or similar program), bulletin-boards programs, operating systems,\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 3\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 5 of 15 Page ID\n #:1077\n\n\n 1 source codes, PDF files, batch files, ASCII files, and all miscellaneous media on\n 2 which they reside and regardless of whether said electronic data exists in an active\n 3 file, deleted file, or file fragment; and\n 4 (e) All items stored on Electronic Media (defined below).\n 5 10. \u201cElectronic Media\u201d means any magnetic or other storage media device\n 6 used to record ESI.\n 7 11. \u201cIn connection with\u201d means concerning, involving, relating to, or in any\n 8 way pertaining to, either directly or indirectly.\n 9 12. \u201cIncluding\u201d and \u201cinclude\u201d means including, but not limited to.\n10\n10 13. \u201cParagraph\u201d or \u201c\u00b6\u201d corresponds to paragraphs in the Complaint.\n11\n11 14. \u201cPerson\u201d means any natural person or any entity or organization.\n12\n12 15. \u201cPlaintiffs\u201d means Lead Plaintiffs Louisiana Sheriffs\u2019 Pension & Relief\n13\n13 Fund and City of Fort Lauderdale Police & Firefighters\u2019 Retirement System.\n14\n14 16. \u201cSedona Conference Definitions\u201d means The Sedona Conference\n15\n15 Glossary: EDiscovery & Digital Information Management (Fifth Edition \u2013 February\n16\n16 2025 Version).\n17\n17 17. \u201cTAVR\u201d means Transcatheter Aortic Valve Replacement artificial heart\n18\n18 valves.\n19\n19 18. \u201cYou\u201d and \u201cYour\u201d means the specific Defendant responding to these\n20\n20 Document Requests.\n21\n21 19. \u201cZovighian\u201d means Defendant Bernard J. Zovighian.\n22\n22 INSTRUCTIONS\n23\n23 1. All discovery requests shall be construed pursuant to the applicable\n24\n24 Federal Rules of Civil Procedure and Local Rules of this Court.\n25\n25 2. These Document Requests call for the production of all responsive\n26\n26 Documents and Communications that are in Your possession, custody, or control,\n27\n27 wherever located, regardless of whether they are possessed directly by You, Your\n28\n28 Advisors, or other persons acting or purporting to act on Your behalf. Your\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 4\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 6 of 15 Page ID\n #:1078\n\n\n 1 obligations pursuant to the Document Requests are not limited or affected by the\n 2 availability of any Document or Communication through any other source. This\n 3 includes all responsive Documents and materials stored in any hard copy library\n 4 maintained by Edwards.\n 5 3. If any portion of any Document or Communication is responsive to any\n 6 Document Request, the entire Document or Communication, including any\n 7 attachments or disclosures, must be produced.\n 8 4. For any responsive Documents or Communications stored in electronic\n 9 format, including email, You will produce those Documents or Communications in\n10\n10 searchable electronic format (e.g., single-page .tiff format with corresponding OCR\n11\n11 or full-text files) through a file transfer protocol website, on CD-ROMs, DVD-\n12\n12 ROMs, or portable or external hard drives, or through some other widely used\n13\n13 electronic or optical storage media. All Microsoft Excel and PowerPoint documents\n14\n14 will be produced in native format, and Plaintiffs reserve the right, as needed, to seek\n15\n15 production of additional Documents, Communications, or categories of Documents\n16\n16 or Communications in native format. All responsive electronic Documents and\n17\n17 Communications will be produced with sufficient metadata to convey where these\n18\n18 items begin and end (including attachments), the original file name, and the original\n19\n19 timestamps and attributes, including the following metadata fields: \u201cBEGBATES,\u201d\n20\n20 \u201cENDBATES,\u201d \u201cBEGATTACH,\u201d \u201cENDATTACH,\u201d \u201cto,\u201d \u201cfrom,\u201d \u201ccc,\u201d \u201cbcc,\u201d\n21\n21 \u201csubject,\u201d \u201ccustodian,\u201d \u201cdate and time sent,\u201d \u201cdate and time received,\u201d \u201ccreation date\n22\n22 and time,\u201d \u201clast modified,\u201d and \u201cMD5HASH.\u201d Timestamp metadata should reflect\n23\n23 the time in the time zone of the custodian from whom the Document or\n24\n24 Communication was collected.\n25\n25 5. To the extent that any portion of these Instructions conflicts with any\n26\n26 ESI protocol entered or to be entered by the Court, the ESI protocol governs.\n27\n27 6. All Documents and Communications should be produced for copying\n28\n28 or inspection as they are kept in the ordinary course of business, or shall be organized\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 5\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 7 of 15 Page ID\n #:1079\n\n\n 1 and labeled to correspond to the specific Document Request(s) to which they are\n 2 responsive. You shall produce Documents and Communications requested herein,\n 3 including electronic Documents and Communications, in the original file folders,\n 4 boxes, or other containers or binders in which such items are found, including the\n 5 title, labels, or other description of each such folder, box, or other container, or attach\n 6 a copy of the Documents or Communications to copies of the file folders from which\n 7 they came. The integrity and internal sequence of the requested Documents and\n 8 Communications within each folder shall not be disturbed or commingled with the\n 9 contents of another folder. All Documents and Communications should be stored,\n10\n10 clipped, stapled, or otherwise arranged in the same form and manner as they were\n11\n11 found. If a Document or Communication is responsive to more than one Document\n12\n12 Request, You are not required to duplicate production.\n13\n13 7. Plaintiffs reserve the right to view the original of any copy of a\n14\n14 Document or Communication provided in response to these Document Requests.\n15\n15 8. You shall produce all Documents and Communications that cannot be\n16\n16 legibly copied in their original form.\n17\n17 9. If any objection is made to any of these Document Requests, the\n18\n18 response shall state with specificity the grounds for the objection, and whether\n19\n19 Documents or Communications are being withheld from inspection and production\n20\n20 on the basis of such objection or whether inspection or production of the responsive\n21\n21 items will occur notwithstanding such objection.\n22\n22 10. If You claim any form of privilege or any other objection, whether\n23\n23 based on statute, common law, or otherwise, as a ground for not producing any\n24\n24 requested Document or Communication, furnish a list identifying each item for\n25\n25 which the privilege or other objection is claimed together with the following\n26\n26 information: a description of the type of Document or Communication (e.g., email,\n27\n27 letter, agreement, memorandum, etc.); date; sender; recipient; all persons to whom\n28\n28 the Document or Communication (or copies thereof) was provided (including their\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 6\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 8 of 15 Page ID\n #:1080\n\n\n 1 job titles and professional affiliation); subject matter; basis upon which a privilege\n 2 or other objection is claimed; and the specific Document Request(s) to which such\n 3 Document or Communication is responsive.\n 4 11. If You claim privilege or any other objection with regard to only part of\n 5 a Document or Communication, produce the part to which there is no claim of\n 6 privilege or objection and furnish a list identifying each item that is partially\n 7 withheld based on a claim of privilege or other objection together with the\n 8 information listed in Instruction No. 12.\n 9 12. If You cannot satisfy any Document Request, either in full or in part,\n10\n10 You shall produce Documents and Communications to the extent possible,\n11\n11 specifying the reason for Your inability to produce further Documents or\n12\n12 Communications.\n13\n13 13. If there are no Documents or Communications responsive to any\n14\n14 particular Document Request or subpart thereof, You shall state so in writing.\n15\n15 14. If any Document or Communication was but is no longer in Your\n16\n16 possession, custody, or control, please state and specify in detail for each such\n17\n17 Document or Communication: a description of the type of Document or\n18\n18 Communication (e.g., email, letter, agreement, memorandum, etc.); date; sender;\n19\n19 recipient; all persons to whom the Document or Communication (or copies thereof)\n20\n20 was provided (including their job titles and professional affiliation); information\n21\n21 contained therein; date upon which it ceased to exist or be in Your possession,\n22\n22 custody, or control; disposition that was made of it; and the identity of all persons\n23\n23 having knowledge of the contents thereof.\n24\n24 15. The terms \u201call,\u201d \u201cany,\u201d and \u201ceach\u201d shall each be construed as\n25\n25 encompassing any and all.\n26\n26 16. The connectives \u201cand\u201d and \u201cor\u201d shall be construed either disjunctively\n27\n27 or conjunctively as necessary to bring within the scope of these Document requests\n28\n28 all responses that might otherwise be construed to be outside their scope.\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 7\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 9 of 15 Page ID\n #:1081\n\n\n 1 17. The use of the singular form of any word includes the plural and vice\n 2 versa.\n 3 18. Unless specifically defined herein, the Document Requests, including\n 4 the terms, words, and language therein, shall be interpreted in a manner consistent\n 5 with their commonly understood meaning in keeping with basic logic and common\n 6 sense.\n 7 19. If no Documents or materials exist that are responsive to a particular\n 8 request, state so in writing.\n 9 20. These Document Requests shall be deemed to be continuing so as to\n10\n10 require supplemental responses from time-to-time up until the date of trial.\n11\n11 RELEVANT TIME PERIOD\n12\n12 Unless otherwise stated in a specific Document Request, all Documents and\n13\n13 Communications requested are for the period from January 1, 2023 through to\n14\n14 February 28, 2025 (the \u201cRelevant Time Period\u201d), and shall include all Documents\n15\n15 and Communications that relate, in whole or in part, to such period even though\n16\n16 dated, prepared or received before or after that period. If a Document or\n17\n17 Communication is not dated and the date of its preparation cannot be determined, it\n18\n18 shall be produced if otherwise responsive to these requests.\n19\n19 REQUESTS FOR PRODUCTION\n20\n20 DOCUMENT REQUEST NO. 1:\n21\n21 All Documents and Communications concerning growth in Edwards\u2019 TAVR\n22\n22 sales during the Relevant Period, including without limitation:\n23\n23 a. Any internal or public projections, guidance, or expectations concerning\n24\n24 TAVR growth or sales;\n25\n25 b. the 2024 Sales Outlook for TAVR;\n26\n26 c. the projection of 8%-10% of Constant Currency Growth for TAVR,\n27\n27 including how it was calculated, the underlying analysis or analyses, and\n28\n28 any assessment, review, analysis, or study concerning that projection;\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 8\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 10 of 15 Page\n ID #:1082\n\n\n 1 d. any headwind or headwinds that impacted or could have impacted TAVR\n 2 growth or sales in any way;\n 3 e. any tailwind or tailwinds that impacted or could have impacted TAVR\n 4 growth or sales in any way;\n 5 f. the market for TAVR, including any analysis, study, or examination of the\n 6 TAVR market;\n 7 g. the statements concerning TAVR growth, sales, guidance, and/or TAVR\n 8 capacity (or lack thereof) made in the February 6, 2024 Form 8-K, the\n 9 February 6, 2024 Earnings Call, the April 25, 2024 Form 8-K, the April\n10\n10 25, 2024 Earnings Call, and the June 5, 2024 Analyst Call. See, e.g., the\n11\n11 Court\u2019s Order Granting in Part and Denying in part Defendants\u2019 Motion to\n12\n12 Dismiss, dated September 19, 2025, ECF No. 72 at 9-11;\n13\n13 h. All meeting minutes, agendas, presentations or notes from any Town Hall\n14\n14 or other internal Edwards meeting concerning TAVR growth, sales,\n15\n15 guidance, and/or TAVR capacity (or lack thereof);\n16\n16 i. All meeting minutes, agendas, presentations, or notes from meetings of the\n17\n17 Board of Directors or any subcommittees of the Board at which TAVR\n18\n18 was discussed, including but not limited to, its performance and/or growth;\n19\n19 and/or\n20\n20 j. the decision to reduce full-year 2024 TAVR sales guidance to 5% to 7%\n21\n21 growth instead of the 8% to 10% growth previously given to investors.\n22\n22\n DOCUMENT REQUEST NO. 2:\n23\n23\n For the time period from March 1, 2020 through to February 28, 2025 and\n24\n24\n unless already produced in response to Document Request No. 1, all Documents and\n25\n25\n Communications concerning any actual or potential constraint(s), limitation(s),\n26\n26\n pressure(s), or restriction(s) on TAVR sales or growth during the Relevant Period,\n27\n27\n including without limitation:\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 9\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 11 of 15 Page\n ID #:1083\n\n\n 1 a. capacity to perform TAVR procedures, including hospital capacity and any\n 2 analysis, study, or examination thereof;\n 3 b. the number of facilities\n 4 c. hospital workflows;\n 5 d. competition by other heart valve products or procedures, including without\n 6 limitation PASCAL and EVOQUE;\n 7 e. the resources, staffing, and/or expense required to perform TAVR\n 8 procedures;\n 9 f. a cap or limit on TAVR hospital centers; and/or\n10\n10 g. All meeting minutes, agendas, presentations or notes from any Town Hall\n11\n11 or other internal Edwards meeting concerning any actual or potential\n12\n12 constraints, limitations, or restrictions on TAVR sales or growth.\n13\n13\n DOCUMENT REQUEST NO. 3:\n14\n14\n For each of the fiscal years of 2021, 2022, 2023, and 2024, Documents and\n15\n15\n Communications concerning the revenues, profits, and/or net sales generated by\n16\n16\n Edwards\u2019 TAVR sales, as well as the percentage of, or contribution to, Edwards\u2019\n17\n17\n total revenues from TAVR sales.\n18\n18\n19\n19 DOCUMENT REQUEST NO. 4:\n20\n20 All Documents and Communications concerning metrics or data concerning\n21\n21 TAVR sales and/or procedure volumes during the Relevant Period, including\n22\n22 Edwards\u2019 internal data, Salesforce data, and/or any tracking, analysis, or\n23\n23 investigation concerning any TAVR-related metrics.\n24\n24\n DOCUMENT REQUEST NO. 5:\n25\n25\n Documents and Communications sufficient to show the timing and reasons\n26\n26\n that Edwards entered into negotiations to acquire Innovalve, JenaValve, and\n27\n27\n Endotronix, or any other companies during the Relevant Period.\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 10\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 12 of 15 Page\n ID #:1084\n\n\n 1 DOCUMENT REQUEST NO. 6:\n 2 All Documents and Communications concerning compensation, bonus, or\n 3 incentive plans for Edwards executives, sales personnel, or other employees,\n 4 including without limitation Zovighian.\n 5\n DOCUMENT REQUEST NO. 7:\n 6\n All Documents and Communications concerning Edwards\u2019 stock price or any\n 7\n movement in Edwards\u2019 stock price during the period from February 6, 2024 through\n 8\n July 29, 2024.\n 9\n\n10\n10 DOCUMENT REQUEST NO. 8:\n11\n11 All Documents and Communications concerning any trade, sale, purchase, or\n12\n12 acquisition by Defendant Zovighian of Edwards stock during the Relevant Period,\n13\n13 including without limitation any 10b5-1 plan and/or the sale by Zovighian of 8,617\n14\n14 shares of Edwards common stock on or about May 30, 2024.\n15\n15\n DOCUMENT REQUEST NO. 9:\n16\n16\n All documents and communications concerning any action(s), remediation(s),\n17\n17\n corrective measure(s), employment decision(s) (including any termination), or other\n18\n18\n response(s) taken concerning the TAVR growth guidance adjustment announced on\n19\n19\n July 24, 2024, as alleged in \u00b6\u00b691-99 of the Complaint.\n20\n20\n21\n21 DOCUMENT REQUEST NO. 10:\n22\n22 All insurance policies or agreements, including directors and officers\u2019 liability\n23\n23 insurance policies or agreements, which are applicable to this Action.\n24\n24\n DOCUMENT REQUEST NO. 11:\n25\n25\n All Documents and Communications that Defendants rely on or intend to rely\n26\n26\n on in this litigation in support of any defense, including any affirmative defenses.\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 11\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 13 of 15 Page\n ID #:1085\n\n\n 1 DOCUMENT REQUEST NO. 12:\n 2 Documents and Communications sufficient to show Edwards\u2019 document\n 3 retention or deletion policies, practices, or procedures in place during the Relevant\n 4 Time Period.\n 5\n DOCUMENT REQUEST NO. 13:\n 6\n All Documents and Communications concerning any documents produced to\n 7\n Defendants by any non-party in connection with this Action, including in response\n 8\n to any subpoena served by Defendants.\n 9\n\n10\n10 DOCUMENT REQUEST NO. 14:\n11\n11 All Documents and Communications concerning any analysis or report\n12\n12 concerning this Action prepared by or on behalf of Defendants, including by any\n13\n13 purported expert and including any related analysis, investigation, examination, or\n14\n14 study.\n15\n15\n DOCUMENT REQUEST NO. 15:\n16\n16\n Unless otherwise produced in response to another Document Request, All\n17\n17\n Documents and Communications concerning the allegations of the Complaint.\n18\n18\n19\n19\n20\n20\n21\n21\n22\n22\n23\n23\n24\n24\n25\n25\n26\n26\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 12\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 14 of 15 Page\n ID #:1086\n\n\n 1 DATED: September 29, 2025 Respectfully submitted,\n 2\n BERNSTEIN LITOWITZ BERGER\n 3 & GROSSMANN LLP\n 4 Jeremy P. Robinson /s/\n Jonathan D. Uslaner (Bar No. 256898)\n 5 2121 Avenue of the Stars, Suite 2575\n Los Angeles, CA 90067\n 6\n Tel: (310) 819-3470\n 7 jonathanu@blbglaw.com\n 8 -and-\n 9 Salvatore J. Graziano (pro hac vice)\n10 Jeremy P. Robinson (pro hac vice)\n10 Thomas Z. Sperber (pro hac vice)\n11\n11 Rebecca S. Temkin (pro hac vice)\n 1251 Avenue of the Americas\n12\n12 New York, NY 10020\n Tel: (212) 554-1400\n13\n13 Fax: (212) 554-1444\n14\n14 Jeremy@blbglaw.com\n Thomas.sperber@blbglaw.com\n15\n15 Rebecca.temkin@blbglaw.com\n16\n16 Counsel for Lead Plaintiffs Louisiana\n Sheriffs\u2019 Pension & Relief Fund and\n17\n17 City of Fort Lauderdale Police &\n Firefighters\u2019 Retirement System\n18\n18\n KLAUSNER, KAUFMAN, JENSEN &\n19\n19 LEVINSON\n20\n20 Robert D. Klausner\n Stuart Kaufman\n21\n21 7080 Northwest Fourth Street\n Plantation, Florida, 33315\n22\n22 Tel: (954) 916-1202\n Fax: (954) 916-1232\n23\n23 bob@robertdklausner.com\n stu@robertdklausner.com\n24\n24\n25\n25 Additional counsel for Lead Plaintiffs\n Louisiana Sheriffs\u2019 Pension & Relief Fund and\n26\n26 City of Fort Lauderdale Police & Firefighters\u2019\n Retirement System\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 13\n\f Case 8:24-cv-02221-AH-KES Document 91-1 Filed 03/31/26 Page 15 of 15 Page\n ID #:1087\n\n\n 1\n\n 2\n\n 3\n\n 4\n\n 5\n\n 6\n\n 7\n\n 8\n\n 9\n\n10\n10\n11\n11\n12\n12\n13\n13\n14\n14\n15\n15\n16\n16\n17\n17\n18\n18\n19\n19\n20\n20\n21\n21\n22\n22\n23\n23\n24\n24\n25\n25\n26\n26\n27\n27\n28\n28\n PLAINTIFFS\u2019 FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS\n CASE NO. 8:24-CV-02221-AH-KES 14\n\f","ocr_status":1,"date_upload":"2026-05-19T22:25:53.596524-07:00","document_number":"91","attachment_number":1,"pacer_doc_id":"031047376925","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 1","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479806723/","id":479806723,"tags":[],"absolute_url":"/docket/69258750/91/2/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-05-19T22:25:33.633938-07:00","date_modified":"2026-05-22T08:52:59.355561-07:00","sha1":"5f72fef6f1c9ebf166da647467845410fc046479","page_count":25,"file_size":344091,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 1 of 25 Page ID\n #:1088\n\n\n\n\n EXHIBIT 2\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 2 of 25 Page ID\n #:1089\n\n 1 LATHAM & WATKINS LLP\n Michele D. Johnson (SBN 198298)\n 2 Kristin N. Murphy (SBN 268285)\n Jordan D. Cook (SBN 293394)\n 3 650 Town Center Drive, 20th Floor\n Costa Mesa, CA 92626\n 4 Telephone: (714) 540-1235\n Email: michele.johnson@lw.com\n 5 Email: kristin.murphy@lw.com\n Email: jordan.cook@lw.com\n 6\n Attorneys for Defendants\n 7\n Edwards Lifesciences Corporation and\n 8 Bernard J. Zovighian\n 9\n UNITED STATES DISTRICT COURT\n 10\n CENTRAL DISTRICT OF CALIFORNIA\n 11\n 12 DHIMANT PATEL, Individually and on Case No. 8:24-cv-02221-AH-KES\n Behalf of All Others Similarly Situated,\n 13\n DEFENDANTS\u2019 RESPONSES AND\n 14 Plaintiff, OBJECTIONS TO PLAINTIFFS\u2019\n v. FIRST SET OF REQUESTS FOR\n 15\n PRODUCTION OF DOCUMENTS\n 16 EDWARDS LIFESCIENCES DIRECTED TO DEFENDANTS\n CORPORATION and BERNARD J.\n 17\n ZOVIGHIAN,\n 18\n Defendants.\n 19\n 20\n 21\n 22\n 23\n 24\n 25\n 26\n 27\n 28\n CASE NO. 8:24-cv-02221-AH-KES\n DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 3 of 25 Page ID\n #:1090\n\n 1 Pursuant to Rule 34 of the Federal Rules of Civil Procedure, Defendants\n 2 Edwards Lifesciences Corp. and Bernard J. Zovighian (collectively \u201cDefendants\u201d),\n 3 by and through their counsel, hereby object and respond to Plaintiffs Louisiana\n 4 Sheriffs\u2019 Pension & Relief Fund\u2019s and City of Fort Lauderdale Police & Firefighters\u2019\n 5 Retirement System\u2019s (\u201cPlaintiffs\u201d) First Set of Requests for the Production of\n 6 Documents Directed to Defendants, (the \u201cRequests\u201d and, each, a \u201cRequest\u201d), as\n 7 follows:\n 8 PRELIMINARY STATEMENT\n 9 Defendants\u2019 responses to the Requests are prepared based on information\n 10 known to Defendants as of the date of these responses. Discovery and investigation\n 11 in the above-captioned action (the \u201cAction\u201d) has just begun, and Defendants\n 12 therefore reserve the right to supplement, clarify, revise, or correct these responses\n 13 should they become aware of any omission, error, or additional information that they\n 14 may subsequently discover and determine to be relevant. Defendants will make\n 15 reasonable efforts to respond to every Request to the extent that it has not been\n 16 objected to and to the extent Defendants understand the Request. If Plaintiffs\n 17 subsequently assert an interpretation of a Request that differs from that given by\n 18 Defendants, then Defendants reserve the right to supplement their objections and\n 19 responses, as necessary. In providing these responses to the Requests, Defendants\n 20 reserve their rights to (i) assert any and all objections to the competency,\n 21 authenticity, relevancy, materiality, or admissibility into evidence of any of the\n 22 responses and objections herein or documents or information produced in response\n 23 to the Requests; and (ii) object to the use of these responses in any proceeding other\n 24 than the above-captioned action.\n 25 GENERAL OBJECTIONS\n 26 The following general objections (\u201cGeneral Objections\u201d) are incorporated\n 27 into each and every response set forth below.\n 28\n CASE NO. 8:24-cv-02221-AH-KES\n 1 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 4 of 25 Page ID\n #:1091\n\n 1 1. Defendants object to Plaintiff\u2019s Definitions, Instructions, and Requests\n 2 to the extent they seek to impose duties, obligations, or burdens on Defendants\n 3 different from or in addition to what is required by the Federal Rules of Civil\n 4 Procedure, the applicable Local Rules of the Central District of California, any\n 5 governing case law, or any other applicable law (the \u201cApplicable Rules\u201d).\n 6 2. Defendants object to each of the Requests to the extent they seek\n 7 information protected by the attorney-client privilege, work product doctrine,\n 8 accountant-client privilege, or any other recognized privilege or confidentiality. If\n 9 one or more documents are produced that are privileged or otherwise protected from\n 10 disclosure, such production is inadvertent and is not intended as a waiver of such\n 11 privilege or protection. Any inadvertent production shall be treated pursuant to the\n 12 terms of the Stipulated Protective Order (the \u201cProtective Order\u201d) and Stipulated\n 13 Order re: Discovery of Electronically Stored Information (the \u201cESI Protocol\u201d) to be\n 14 agreed-upon by the Parties and the Federal Rules of Civil Procedure 26(b)(5)(B).\n 15 3. Defendants will produce confidential and proprietary information, if\n 16 any, subject to the protections of an adequate Protective Order. Defendants object\n 17 to the Requests to the extent they seek information protected as trade secrets or\n 18 confidential, proprietary, business, or commercial information that is exempt from\n 19 disclosure under Federal Rule 26(c) or any other applicable evidentiary, statutory or\n 20 common law privilege.\n 21 4. Defendants intend to and reserve their rights to manage the burden and\n 22 costs associated with searching for responsive documents by using appropriate scope\n 23 limitations and search methods (such as search terms, custodian limitations, date\n 24 range filters, and any other advanced search methodology and/or technology-\n 25 assisted review) to limit the search, review, processing, and production of documents\n 26 responsive to the Requests (\u201cSearch Protocol\u201d). Defendants anticipate that the\n 27 Search Protocol may involve searches of electronic files of a set of agreed-upon\n 28 document custodians using an agreed-upon date range and search terms and/or a\n\n CASE NO. 8:24-cv-02221-AH-KES\n 2 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 5 of 25 Page ID\n #:1092\n\n 1 good-faith, reasonably targeted search for readily identifiable documents from a\n 2 reasonably accessible central repository, depending on the Request. Defendants will\n 3 meet and confer regarding the parameters and scope of the Search Protocol.\n 4 5. Defendants object to each of the Requests to the extent they call for the\n 5 disclosure of third-party confidential information and/or the invasion of the right to\n 6 privacy of third parties. Defendants further object to each of the Requests to the\n 7 extent they seek information protected by any U.S., state, or foreign privacy law or\n 8 regulation, such as information that is private or confidential under the Constitution\n 9 of the State of California, including but not limited to article 1, section 1, production\n 10 of which would violate the privacy rights of Defendants and/or any other person\n 11 and/or entity. Defendants will not produce information that is private or confidential\n 12 under the California Constitution.\n 13 6. Defendants object to each of the Requests to the extent they call for\n 14 legal conclusions, present questions of pure law, or call for Defendants or its counsel\n 15 to disclose its opinions and/or work product. None of the responses herein are\n 16 intended to provide any legal conclusions or disclose privileged or protected\n 17 information.\n 18 7. Defendants object to each of the Requests to the extent they exceed the\n 19 limited scope of phased discovery the Court noted in its Order Granting in Part and\n 20 Denying in Part Defendants\u2019 Motion to Dismiss, including because they require the\n 21 production of documents unrelated to the \u201cissue of Zovighian\u2019s knowledge and\n 22 scienter\u201d (Dkt. 72 (\u201cOrder\u201d) at 21, n.10).\n 23 8. By responding to the Requests, Defendants do not concede the\n 24 relevance or admissibility of the information requested nor do Defendants adopt the\n 25 legal characterizations of the terms and words used in the Requests. Similarly, by\n 26 responding to the Requests, Defendants do not admit the existence of any responsive\n 27 information or facts set forth or assumed by such Requests. The specific objections\n 28 to each Request are in addition to the limitations and objections set forth in this\n\n CASE NO. 8:24-cv-02221-AH-KES\n 3 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 6 of 25 Page ID\n #:1093\n\n 1 section. The absence of a reference to the foregoing objections in response to any\n 2 Request should not be construed as a waiver of the General Objection to a specific\n 3 Request.\n 4 OBJECTIONS TO PLAINTIFFS\u2019 DEFINITIONS AND INSTRUCTIONS\n 5 1. Defendants object to the Definitions and Instructions insofar as they\n 6 purport to alter the plain meaning or scope of any Request on the ground that such\n 7 alteration renders the Request vague, ambiguous, unduly broad, and uncertain.\n 8 2. Defendants object to the definitions of the terms \u201cCompany,\u201d\n 9 \u201cEdwards,\u201d and \u201cDefendants\u201d on the grounds that they are overbroad, unduly\n 10 burdensome, and not proportional to the needs of the case, to the extent that they\n 11 purport to impose burdens or obligations beyond the production of documents within\n 12 a Defendant\u2019s possession, custody, or control. In particular, inclusion of \u201call of its\n 13 present and former divisions, subsidiaries, affiliates, predecessors, successors,\n 14 agents, representatives, and its present and former officers, directors, and\n 15 employees\u201d cause the Requests to implicate burdens and expenses that outweigh any\n 16 benefit, are disproportionate to the needs of this case, and seek materials that are not\n 17 relevant to any party\u2019s claim or defense in this case. Defendants will meet and confer\n 18 with Plaintiffs concerning appropriate custodians and sources for which negotiated\n 19 search parameters will be applied.\n 20 3. Defendants object to the definitions of the terms \u201cCommunication,\u201d\n 21 \u201cConcerning,\u201d \u201cDocument,\u201d \u201cElectronically Stored Information,\u201d \u201cESI,\u201d\n 22 \u201cElectronic Media,\u201d \u201cIn connection with,\u201d and \u201cIncluding\u201d on the grounds that they\n 23 are overbroad, unduly burdensome, and not proportional to the needs of the case, to\n 24 the extent that they purport to impose burdens and obligations to conduct anything\n 25 beyond a reasonable search for responsive documents, or to otherwise impose\n 26 conditions, obligations, or burdens beyond those required by the Applicable Rules.\n 27 Defendants will produce documents in accordance with the terms of a forthcoming\n 28 Protective Order and negotiated ESI Protocol.\n\n CASE NO. 8:24-cv-02221-AH-KES\n 4 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 7 of 25 Page ID\n #:1094\n\n 1 4. Defendants object to the definition of the term \u201cTAVR\u201d to the extent it\n 2 differs to how the Company commonly uses that term. Defendants will interpret\n 3 \u201cTAVR\u201d to mean the Transcatheter Aortic Valve Replacement product group as the\n 4 term TAVR is used in the Company\u2019s filings with the Securities and Exchange\n 5 Commission.\n 6 5. Defendants object to Instruction Nos. 2, 4, 6, 12, and 14 on the grounds\n 7 that they are overbroad, unduly burdensome, and not proportional to the needs of the\n 8 case, to the extent that they purport to impose burdens or obligations beyond the\n 9 production of documents within a Defendant\u2019s possession, custody, or control, and\n 10 to the extent they purport to impose burdens and obligations to conduct anything\n 11 beyond a reasonable search for responsive documents, or to otherwise impose\n 12 conditions, obligations, or burdens beyond those required by the Applicable Rules\n 13 and the ESI Protocol. Defendants will meet and confer with Plaintiffs concerning\n 14 appropriate custodians and sources for which negotiated search parameters will be\n 15 applied, and Defendants will produce documents in accordance with the terms of a\n 16 forthcoming Protective Order and negotiated ESI Protocol.\n 17 6. Defendants object to Instruction Nos. 10 and 11 to the extent they\n 18 purport to require Defendants to impose additional burdens or obligations beyond\n 19 those required by the Applicable Rules. Defendants will serve a privilege log\n 20 consistent with the Applicable Rules and the terms of a forthcoming Protective Order\n 21 and negotiated ESI Protocol.\n 22 7. The additional specific objections to each Request for Production set\n 23 forth below are in addition to the limitations and objections set forth in this section.\n 24 The absence of a reference to the foregoing limitations and objections in response to\n 25 any Request for Production should not be construed as a waiver of such limitations\n 26 and objections.\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 5 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 8 of 25 Page ID\n #:1095\n\n 1 OBJECTION TO RELEVANT TIME PERIOD\n 2 Defendants object to Plaintiffs\u2019 definition of the \u201cRelevant Time\n 3 Period\u201d on the ground that it is overbroad, unduly burdensome, and seeks\n 4 information disproportionate to the needs of the case, and is not appropriately\n 5 tailored to the claims asserted in the Action because it spans approximately 13\n 6 months before the putative Class Period begins and approximately 7 months after it\n 7 ends. Except as otherwise noted by Defendants in response to a particular Request,\n 8 Defendants will interpret the relevant time period to be December 1, 2023 to August\n 9 31, 2024 (hereinafter referred to as the \u201cModified Time Period\u201d).\n 10 SPECIFIC RESPONSES AND OBJECTIONS\n 11 Without waiving or limiting in any manner any of the foregoing\n 12 General Objections and Objections to Plaintiffs\u2019 Definitions and Instructions,\n 13 Defendants respond to the specific Requests as follows:\n 14 REQUEST FOR PRODUCTION NO. 1:\n 15 All Documents and Communications concerning growth in Edwards\u2019\n 16 TAVR sales during the Relevant Period, including without limitation:\n 17 a. Any internal or public projections, guidance, or expectations\n 18 concerning TAVR growth or sales;\n 19 b. the 2024 Sales Outlook for TAVR;\n 20 c. the projection of 8%-10% of Constant Currency Growth for TAVR,\n 21 including how it was calculated, the underlying analysis or analyses,\n 22 and any assessment, review, analysis, or study concerning that\n 23 projection;\n 24 d. any headwind or headwinds that impacted or could have impacted\n 25 TAVR growth or sales in any way;\n 26 e. any tailwind or tailwinds that impacted or could have impacted TAVR\n 27 growth or sales in any way;\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 6 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 9 of 25 Page ID\n #:1096\n\n 1 f. the market for TAVR, including any analysis, study, or examination of\n 2 the TAVR market;\n 3 g. the statements concerning TAVR growth, sales, guidance, and/or\n 4 TAVR capacity (or lack thereof) made in the February 6, 2024 Form 8-\n 5 K, the February 6, 2024 Earnings Call, the April 25, 2024 Form 8-K,\n 6 the April 25, 2024 Earnings Call, and the June 5, 2024 Analyst Call.\n 7 See, e.g., the Court\u2019s Order Granting in Part and Denying in part\n 8 Defendants\u2019 Motion to Dismiss, dated September 19, 2025, ECF No.\n 9 72 at 9-11;\n 10 h. All meeting minutes, agendas, presentations or notes from any Town\n 11 Hall or other internal Edwards meeting concerning TAVR growth,\n 12 sales, guidance, and/or TAVR capacity (or lack thereof);\n 13 i. All meeting minutes, agendas, presentations, or notes from meetings of\n 14 the Board of Directors or any subcommittees of the Board at which\n 15 TAVR was discussed, including but not limited to, its performance\n 16 and/or growth; and/or\n 17 j. the decision to reduce full-year 2024 TAVR sales guidance to 5% to\n 18 7% growth instead of the 8% to 10% growth previously given to\n 19 investors.\n 20 RESPONSE TO REQUEST FOR PRODUCTION NO. 1:\n 21 Defendants incorporate the Preliminary Statement, General Objections,\n 22 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 23 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 24 is unduly burdensome, overly broad, and disproportionate to the needs of the case,\n 25 including because it fails to take into account the Court\u2019s Order, which proposed\n 26 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 27 before any other discovery. Defendants further object to the Request as overbroad\n 28 because it seeks documents concerning statements made by defendants who have\n\n CASE NO. 8:24-cv-02221-AH-KES\n 7 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 10 of 25 Page\n ID #:1097\n\n 1 been dismissed from the Action. Defendants further object to the Request on the\n 2 grounds that it is vague and ambiguous, including because the undefined terms\n 3 \u201cexpectations,\u201d \u201cthe 2024 Sales Outlook,\u201d \u201cany headwind . . . that could have\n 4 impacted,\u201d \u201cany tailwind . . . that could have impacted,\u201d and \u201cmarket for TAVR\u201d\n 5 are undefined, ambiguous, and unclear. Defendants further object to the Request to\n 6 the extent it seeks confidential and proprietary information belonging to third parties\n 7 or information otherwise outside of Defendants\u2019 custody and control. Defendants\n 8 further object to the Request to the extent it seeks the production of documents\n 9 protected from discovery by the attorney-client privilege, the work-product doctrine,\n 10 or any other applicable privilege. Defendants further object to the Request on the\n 11 grounds that it calls for the production of documents within the public domain and\n 12 equally available to Plaintiffs.\n 13 Subject to and without waiver of the above General and Specific\n 14 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 15 mutually agreeable search protocol and agreement regarding the phasing of\n 16 discovery, Defendants will search for and produce non-privileged, responsive\n 17 documents within their possession, custody, or control from the Modified Time\n 18 Period.\n 19 REQUEST FOR PRODUCTION NO. 2:\n 20 For the time period from March 1, 2020 through to February 28, 2025 and\n 21 unless already produced in response to Document Request No. 1, all Documents and\n 22 Communications concerning any actual or potential constraint(s), limitation(s),\n 23 pressure(s), or restriction(s) on TAVR sales or growth during the Relevant Period,\n 24 including without limitation:\n 25 a. capacity to perform TAVR procedures, including hospital capacity and\n 26 any analysis, study, or examination thereof;\n 27 b. the number of facilities\n 28 c. hospital workflows;\n\n CASE NO. 8:24-cv-02221-AH-KES\n 8 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 11 of 25 Page\n ID #:1098\n\n 1 d. competition by other heart valve products or procedures, including\n 2 without limitation PASCAL and EVOQUE;\n 3 e. the resources, staffing, and/or expense required to perform TAVR\n 4 procedures;\n 5 f. a cap or limit on TAVR hospital centers; and/or\n 6 g. All meeting minutes, agendas, presentations or notes from any Town\n 7 Hall or other internal Edwards meeting concerning any actual or\n 8 potential constraints, limitations, or restrictions on TAVR sales or\n 9 growth.\n 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 3:\n 11 Defendants incorporate the Preliminary Statement, General Objections,\n 12 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 13 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 14 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 15 including because it fails to take into account the Court\u2019s Order, which proposed\n 16 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 17 before any other discovery. Defendants further object to the Request on the grounds\n 18 that it is vague and ambiguous, including because the terms, \u201ccapacity to perform\n 19 TAVR procedures,\u201d \u201chospital workflows,\u201d and \u201ca cap or limit on TAVR hospital\n 20 centers,\u201d are undefined and unclear, and because \u201cthe number of facilities\u201d is\n 21 unintelligible. Defendants further object to the Request to the extent it seeks\n 22 confidential and proprietary information belonging to third parties or information\n 23 otherwise outside of Defendants\u2019 custody and control. Defendants further object to\n 24 the Request to the extent it seeks the production of documents that are protected\n 25 from discovery by the attorney-client privilege, the work-product doctrine, or any\n 26 other applicable privilege.\n 27 Subject to and without waiver of the above General and Specific\n 28 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n\n CASE NO. 8:24-cv-02221-AH-KES\n 9 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 12 of 25 Page\n ID #:1099\n\n 1 mutually agreeable search protocol and agreement regarding the phasing of\n 2 discovery, Defendants will search for and produce non-privileged, responsive\n 3 documents within their possession, custody, or control from the Modified Time\n 4 Period.\n 5 REQUEST FOR PRODUCTION NO. 4:\n 6 For each of the fiscal years of 2021, 2022, 2023, and 2024, Documents\n 7 and Communications concerning the revenues, profits, and/or net sales generated by\n 8 Edwards\u2019 TAVR sales, as well as the percentage of, or contribution to, Edwards\u2019\n 9 total revenues from TAVR sales.\n 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 3:\n 11 Defendants incorporate the Preliminary Statement, General Objections,\n 12 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 13 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 14 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 15 including because it fails to take into account the Court\u2019s Order, which proposed\n 16 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 17 before any other discovery. Defendants further object to the Request on the grounds\n 18 that it is vague and ambiguous, including because the term, \u201cconcerning . . . the\n 19 percentage of, or contribution to, Edwards\u2019 total revenues from TAVR sales,\u201d is\n 20 unclear and unreasonably unconstrained in scope. Defendants further object to the\n 21 Request to the extent it seeks the production of documents that are protected from\n 22 discovery by the attorney-client privilege, the work-product doctrine, or any other\n 23 applicable privilege. Defendants further object to the Request on the grounds that it\n 24 calls for the production documents within the public domain and equally available\n 25 to Plaintiffs.\n 26 Subject to and without waiver of the above General and Specific\n 27 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 28 mutually agreeable search protocol and agreement regarding the phasing of\n\n CASE NO. 8:24-cv-02221-AH-KES\n 10 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 13 of 25 Page\n ID #:1100\n\n 1 discovery, Defendants will search for and produce non-privileged, responsive\n 2 documents within their possession, custody, or control from the Modified Time\n 3 Period.\n 4 REQUEST FOR PRODUCTION NO. 5:\n 5 All Documents and Communications concerning metrics or data\n 6 concerning TAVR sales and/or procedure volumes during the Relevant Period,\n 7 including Edwards\u2019 internal data, Salesforce data, and/or any tracking, analysis, or\n 8 investigation concerning any TAVR-related metrics.\n 9 RESPONSE TO REQUEST FOR PRODUCTION NO. 4:\n 10 Defendants incorporate the Preliminary Statement, General Objections,\n 11 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 12 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 13 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 14 including because it fails to take into account the Court\u2019s Order, which proposed\n 15 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 16 before any other discovery. Defendants further object to the Request on the grounds\n 17 that it is vague and ambiguous, including because the terms \u201cmetrics or data\u201d and\n 18 \u201cSalesforce data, and/or any tracking, analysis, or investigation\u201d are undefined and\n 19 unclear, and the Request does not identify what \u201cmetrics or data\u201d are sought.\n 20 Defendants further object to the Request to the extent it seeks confidential and\n 21 proprietary information of third parties or information otherwise outside of\n 22 Defendants\u2019 custody and control. Defendants further object to the Request on the\n 23 ground that it is duplicative of Request Nos. 1 and 2.\n 24 Subject to and without waiver of the above General and Specific\n 25 objections, Defendants respond as follows: Defendants will meet and confer\n 26 regarding a reasonable scope for this Request.\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 11 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 14 of 25 Page\n ID #:1101\n\n 1 REQUEST FOR PRODUCTION NO. 5:\n 2 Documents and Communications sufficient to show the timing and\n 3 reasons that Edwards entered into negotiations to acquire Innovalve, JenaValve, and\n 4 Endotronix, or any other companies during the Relevant Period.\n 5 RESPONSE TO REQUEST FOR PRODUCTION NO. 5:\n 6 Defendants incorporate the Preliminary Statement, General Objections,\n 7 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 8 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 9 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 10 including because it fails to take into account the Court\u2019s Order, which proposed\n 11 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 12 before any other discovery. Defendants further object to the Request as overbroad\n 13 because it seeks documents concerning theories of liability the Court rejected in its\n 14 Order, including the \u201cInnovalve,\u201d \u201cJenaValve,\u201d and \u201cEndotronix\u201d \u201cacqui[sitions]\u201d\n 15 (see Order at 20-23), and information about unnamed \u201cother companies\u201d that have\n 16 no bearing on the claims and defenses at issue here. Defendants further object to the\n 17 Request on the grounds that it is vague and ambiguous, including because the term,\n 18 \u201cother companies,\u201d is unclear and undefined. Defendants further object to the\n 19 Request to the extent it seeks confidential and proprietary information of third parties\n 20 or information otherwise outside of Defendants\u2019 custody and control. Defendants\n 21 further object to the Request to the extent it seeks the production of documents that\n 22 are protected from discovery by the attorney-client privilege, the work-product\n 23 doctrine, or any other applicable privilege.\n 24 Subject to and without waiver of the above General and Specific\n 25 objections, Defendants respond as follows: Defendants will meet and confer\n 26 regarding a reasonable scope for this Request.\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 12 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 15 of 25 Page\n ID #:1102\n\n 1 REQUEST FOR PRODUCTION NO. 6:\n 2 All Documents and Communications concerning compensation, bonus, or\n 3 incentive plans for Edwards executives, sales personnel, or other employees,\n 4 including without limitation Zovighian.\n 5 RESPONSE TO REQUEST FOR PRODUCTION NO. 6:\n 6 Defendants incorporate the Preliminary Statement, General Objections,\n 7 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 8 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 9 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 10 including because it fails to take into account the Court\u2019s Order, which proposed\n 11 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 12 before any other discovery. Defendants further object to the Request as overbroad\n 13 because it seeks documents concerning theories of liability the Court rejected in its\n 14 Order, including \u201ccompensation packages\u201d (see Order at 20-21), and information\n 15 about \u201ccompensation\u201d for unidentified \u201cother employees\u201d without regard to their\n 16 relevance to the Action. Defendants further object to the Request on the grounds\n 17 that it is vague and ambiguous, including because the terms, \u201cEdwards executives,\u201d\n 18 \u201csales personnel,\u201d and \u201cother employees,\u201d are undefined and unclear as to who they\n 19 purport to encompass.\n 20 Subject to and without waiver of the above General and Specific\n 21 objections, Defendants respond as follows: Defendants will meet and confer\n 22 regarding a reasonable scope for this Request.\n 23 REQUEST FOR PRODUCTION NO. 7:\n 24 All Documents and Communications concerning Edwards\u2019 stock price or any\n 25 movement in Edwards\u2019 stock price during the period from February 6, 2024 through\n 26 July 29, 2024.\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 13 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 16 of 25 Page\n ID #:1103\n\n 1 RESPONSE TO REQUEST FOR PRODUCTION NO. 7:\n 2 Defendants incorporate the Preliminary Statement, General Objections,\n 3 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 4 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 5 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 6 including because it fails to take into account the Court\u2019s Order, which proposed\n 7 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 8 before any other discovery. Defendants further object to the Request as overbroad\n 9 because it seeks \u201cAll\u201d documents \u201cconcerning Edwards\u2019 stock price or any\n 10 movement in Edwards\u2019 stock price,\u201d regardless of whether the documents have any\n 11 bearing on the issues, claims, or defenses in this Action and without regard to\n 12 whether less than \u201cAll\u201d of such documents would be sufficient. Defendants further\n 13 object to the Request to the extent it seeks the production of documents that are\n 14 protected from discovery by the attorney-client privilege, the work-product doctrine,\n 15 or any other applicable privilege. Defendants further object to the Request on the\n 16 grounds that it calls for the production of documents within the public domain and\n 17 equally available to Plaintiffs.\n 18 Subject to and without waiver of the above General and Specific\n 19 objections, Defendants respond as follows: Defendants will meet and confer\n 20 regarding a reasonable scope for this Request.\n 21 REQUEST FOR PRODUCTION NO. 8:\n 22 All Documents and Communications concerning any trade, sale, purchase, or\n 23 acquisition by Defendant Zovighian of Edwards stock during the Relevant Period,\n 24 including without limitation any 10b5-1 plan and/or the sale by Zovighian of 8,617\n 25 shares of Edwards common stock on or about May 30, 2024.\n 26 RESPONSE TO REQUEST FOR PRODUCTION NO. 8:\n 27 Defendants incorporate the Preliminary Statement, General Objections,\n 28 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n\n CASE NO. 8:24-cv-02221-AH-KES\n 14 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 17 of 25 Page\n ID #:1104\n\n 1 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 2 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 3 including because it fails to take into account the Court\u2019s Order, which proposed\n 4 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 5 before any other discovery. Defendants further object to the Request as overbroad\n 6 because it seeks documents concerning theories of liability the Court rejected in its\n 7 Order, including \u201cZovighian\u2019s stock sale\u201d (see Order at 20-21). Defendants further\n 8 object to the extent that it seeks the production of documents that are protected from\n 9 discovery by the attorney-client privilege, the work-product doctrine, or any other\n 10 applicable privilege. Defendants further object to the Request on the grounds that it\n 11 calls for the production of documents within the public domain and equally available\n 12 to Plaintiffs.\n 13 Subject to and without waiver of the above General and Specific\n 14 objections, Defendants responds as follows: Defendants will meet and confer\n 15 regarding a reasonable scope for this Request.\n 16 REQUEST FOR PRODUCTION NO. 9:\n 17 All documents and communications concerning any action(s), remediation(s),\n 18 corrective measure(s), employment decision(s) (including any termination), or other\n 19 response(s) taken concerning the TAVR growth guidance adjustment announced on\n 20 July 24, 2024, as alleged in \u00b6\u00b691-99 of the Complaint.\n 21 RESPONSE TO REQUEST FOR PRODUCTION NO. 9:\n 22 Defendants incorporate the Preliminary Statement, General Objections,\n 23 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 24 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 25 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 26 including because it fails to take into account the Court\u2019s Order, which proposed\n 27 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 28 before any other discovery. Defendants further object to the Request because it\n\n CASE NO. 8:24-cv-02221-AH-KES\n 15 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 18 of 25 Page\n ID #:1105\n\n 1 seeks documents that are not relevant to any party\u2019s claims or defenses, including\n 2 \u201cremediation\u201d and \u201ccorrective measure(s).\u201d Defendants further object to the\n 3 Request on the grounds that it is vague and ambiguous, including because the terms,\n 4 \u201caction,\u201d \u201cremediation,\u201d \u201ccorrective measure,\u201d and \u201cother response,\u201d are unclear,\n 5 undefined, and unreasonably broad in scope. Defendants further object to the\n 6 Request to the extent it seeks the production of documents that are protected from\n 7 discovery by the attorney-client privilege, the work-product doctrine, or any other\n 8 applicable privilege. Defendants further object to the Request on the grounds that it\n 9 calls for the production of documents within the public domain and equally available\n 10 to Plaintiffs.\n 11 Subject to and without waiver of the above General and Specific\n 12 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 13 mutually agreeable search protocol and agreement regarding the phasing of\n 14 discovery, Defendants will search for and produce non-privileged, responsive\n 15 documents within their possession, custody, or control from the Modified Time\n 16 Period.\n 17 REQUEST FOR PRODUCTION NO. 10:\n 18 All insurance policies or agreements, including directors and officers\u2019 liability\n 19 insurance policies or agreements, which are applicable to this Action.\n 20 RESPONSE TO REQUEST FOR PRODUCTION NO. 10:\n 21 Defendants incorporate the Preliminary Statement, General Objections,\n 22 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 23 as if set forth fully herein.\n 24 Subject to and without waiver of the above General and Specific\n 25 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 26 mutually agreeable search protocol and agreement regarding the phasing of\n 27 discovery, Defendants will search for and produce non-privileged, responsive\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 16 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 19 of 25 Page\n ID #:1106\n\n 1 documents within their possession, custody, or control from the Modified Time\n 2 Period.\n 3 REQUEST FOR PRODUCTION NO. 11:\n 4 All Documents and Communications that Defendants rely on or intend to rely\n 5 on in this litigation in support of any defense, including any affirmative defenses.\n 6 RESPONSE TO REQUEST FOR PRODUCTION NO. 11:\n 7 Defendants incorporate the Preliminary Statement, General Objections,\n 8 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 9 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 10 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 11 including because it fails to take into account the Court\u2019s Order, which proposed\n 12 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 13 before any other discovery. Defendants further object to the Request as premature.\n 14 Subject to and without waiver of the above General and Specific\n 15 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 16 mutually agreeable search protocol and agreement regarding the phasing of\n 17 discovery, Defendants will search for and produce non-privileged, responsive\n 18 documents within their possession, custody, or control from the Modified Time\n 19 Period.\n 20 REQUEST FOR PRODUCTION NO. 12:\n 21 Documents and Communications sufficient to show Edwards\u2019 document\n 22 retention or deletion policies, practices, or procedures in place during the Relevant\n 23 Time Period.\n 24 RESPONSE TO REQUEST FOR PRODUCTION NO. 12:\n 25 Defendants incorporate the Preliminary Statement, General Objections,\n 26 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 27 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 28 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n\n CASE NO. 8:24-cv-02221-AH-KES\n 17 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 20 of 25 Page\n ID #:1107\n\n 1 including because it fails to take into account the Court\u2019s Order, which proposed\n 2 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 3 before any other discovery. Defendants further object to the Request to the extent it\n 4 seeks \u201cEdwards\u2019 document retention or deletion policies, practices, or procedures\u201d\n 5 without reasonable limitation, including with respect to the location, division,\n 6 program, product, or group for which \u201cpolicies, practices, or procedures\u201d are sought.\n 7 Defendants further object to the Request to the extent it seeks the production of\n 8 documents that are protected from discovery by the attorney-client privilege, the\n 9 work-product doctrine, or any other applicable privilege.\n 10 Subject to and without waiver of the above General and Specific\n 11 objections, Defendants respond as follows: Defendants will meet and confer\n 12 regarding a reasonable scope for this Request.\n 13 REQUEST FOR PRODUCTION NO. 13:\n 14 All Documents and Communications concerning any documents produced to\n 15 Defendants by any non-party in connection with this Action, including in response\n 16 to any subpoena served by Defendants.\n 17 RESPONSE TO REQUEST FOR PRODUCTION NO. 13:\n 18 Defendants incorporate the Preliminary Statement, General Objections,\n 19 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 20 as if set forth fully herein.\n 21 Subject to and without waiver of the above General and Specific\n 22 objections, Defendants respond as follows: subject to the parties\u2019 agreement\n 23 regarding the phasing of discovery, Defendants will produce documents in\n 24 accordance with their obligations under the Applicable Rules.\n 25 REQUEST FOR PRODUCTION NO. 14:\n 26 All Documents and Communications concerning any analysis or report\n 27 concerning this Action prepared by or on behalf of Defendants, including by any\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 18 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 21 of 25 Page\n ID #:1108\n\n 1 purported expert and including any related analysis, investigation, examination, or\n 2 study.\n 3 RESPONSE TO REQUEST FOR PRODUCTION NO. 14:\n 4 Defendants incorporate the Preliminary Statement, General Objections,\n 5 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 6 as if set forth fully herein. Defendants object to the Request on the grounds that it\n 7 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 8 including because it fails to take into account the Court\u2019s Order, which proposed\n 9 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 10 before any other discovery. Defendants further object to the Request on the grounds\n 11 that it is premature. Defendants further object to the Request to the extent it seeks\n 12 the production of documents that are protected from discovery by the attorney-client\n 13 privilege, the work-product doctrine, or any other applicable privilege.\n 14 Subject to and without waiver of the above General and Specific\n 15 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 16 mutually agreeable search protocol and agreement regarding the phasing of\n 17 discovery, Defendants will produce non-privileged, responsive documents within\n 18 their possession, custody, or control from the Modified Time Period, and in\n 19 accordance with their obligations under the Applicable Rules, and on the timeline\n 20 contemplated by the Applicable Rules and any scheduling orders entered in the\n 21 Action.\n 22 REQUEST FOR PRODUCTION NO. 15:\n 23 Unless otherwise produced in response to another Document Request, All\n 24 Documents and Communications concerning the allegations of the Complaint.\n 25 RESPONSE TO REQUEST FOR PRODUCTION NO. 15:\n 26 Defendants incorporate the Preliminary Statement, General Objections,\n 27 Objections to Definitions and Instructions, and Objection to Relevant Time Period\n 28 as if set forth fully herein. Defendants object to the Request on the grounds that it\n\n CASE NO. 8:24-cv-02221-AH-KES\n 19 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 22 of 25 Page\n ID #:1109\n\n 1 is unduly burdensome, overly broad, disproportionate to the needs of the case,\n 2 including because it fails to take into account the Court\u2019s Order, which proposed\n 3 \u201cphased discovery limited to the issue of Zovighian\u2019s knowledge and scienter\u201d\n 4 before any other discovery. The Request is further overbroad because it seeks\n 5 documents that are not relevant to any party\u2019s remaining claims or defenses,\n 6 including documents concerning theories of liability the Court rejected. Defendants\n 7 further object to the Request as vague and ambiguous, including because it seeks\n 8 \u201cAll\u201d documents \u201cconcerning the allegations.\u201d Defendants further object to the\n 9 Request on the grounds that it is premature. Defendants further object to the Request\n 10 to the extent it seeks the production of documents that are protected from discovery\n 11 by the attorney-client privilege, the work-product doctrine, or any other applicable\n 12 privilege.\n 13 Subject to and without waiver of the above General and Specific\n 14 objections, Defendants respond as follows: subject to the parties\u2019 execution of a\n 15 mutually agreeable search protocol and agreement regarding the phasing of\n 16 discovery, Defendants will search for and produce non-privileged, responsive\n 17 documents within their possession, custody, or control from the Modified Time\n 18 Period.\n 19\n 20\n 21\n 22\n 23\n 24\n 25\n 26\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 20 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 23 of 25 Page\n ID #:1110\n\n 1 Dated: October 29, 2025 LATHAM & WATKINS LLP\n 2\n By: / Kristin N. Murphy\n 3 Kristin N. Murphy\n Kristin.Murphy@lw.com\n 4\n Michele D. Johnson\n 5 Michele.Johnson@lw.com\n Jordan D. Cook\n 6\n Jordan.Cook@lw.com\n 7 650 Town Center Dr., 20th Fl.\n Costa Mesa, CA 92626-1925\n 8\n (714) 540-1235\n 9\n Attorneys for Defendants Edwards\n 10\n Lifesciences Corporation and Bernard\n 11 J. Zovighian\n 12\n 13\n 14\n 15\n 16\n 17\n 18\n 19\n 20\n 21\n 22\n 23\n 24\n 25\n 26\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n 21 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 24 of 25 Page\n ID #:1111\n\n 1 PROOF OF SERVICE\n 2\n I am employed in the County of Los Angeles, State of California. I am over\n 3 the age of 18 years and not a party to this action. My business address is Latham\n 4 & Watkins LLP, 12670 High Bluff Drive, San Diego, California 92130.\n 5 On October 29, 2025, I caused the following document(s) to be served:\n 6\n DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO PLAINTIFFS\u2019\n 7 FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS\n 8 DIRECTED TO DEFENDANTS\n 9 via electronic mail delivery to the person(s), address(es), and email address(es) set\n 10 forth below:\n 11 BERNSTEIN LITOWITZ\n BERGER & GROSSMAN\n 12\n Jonathan D. Uslaner\n 13 jonathanu@blbglaw.com\n 14 2121 Avenue of the Stars, Suite 2575\n Los Angeles, CA 90067\n 15 Tel: (310) 819-3481\n 16\n Salvatore J. Graziano (pro hac vice\n 17\n forthcoming)\n 18 salvatore@blbglaw.com\n 19 Jeremy P. Robinson (pro hac vice)\n jeremy@blbglaw.com\n 20\n Thomas Z. Sperber (pro hac vice)\n 21 thomas.sperber@blbglaw.com\n 22 1251 Avenue of the Americas\n New York, NY 10020\n 23 Tel: (212) 554-1400\n 24\n Counsel for Lead Plaintiffs Louisiana\n 25 Sheriffs\u2019 Pension & Relief Fund and\n 26 City of Fort Lauderdale Police &\n Firefighters\u2019 Retirement System\n 27\n 28\n CASE NO. 8:24-cv-02221-AH-KES\n 1 DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\fCase 8:24-cv-02221-AH-KES Document 91-2 Filed 03/31/26 Page 25 of 25 Page\n ID #:1112\n\n 1 I declare that I am employed in the office of a member of the Bar of, or\n 2 permitted to practice before, this Court at whose direction the service was made and\n declare under penalty of perjury that the foregoing is true and correct.\n 3\n 4\n Executed on October 29, 2025, at San Diego, California.\n 5\n 6\n 7 Jaime M. Garcia\n 8\n 9\n 10\n 11\n 12\n 13\n 14\n 15\n 16\n 17\n 18\n 19\n 20\n 21\n 22\n 23\n 24\n 25\n 26\n 27\n 28\n\n CASE NO. 8:24-cv-02221-AH-KES\n DEFENDANTS\u2019 RESPONSES AND OBJECTIONS TO\n REQUESTS FOR PRODUCTION OF DOCUMENTS\n\f","ocr_status":1,"date_upload":"2026-05-19T22:25:56.259870-07:00","document_number":"91","attachment_number":2,"pacer_doc_id":"031047376926","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 2","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479806724/","id":479806724,"tags":[],"absolute_url":"/docket/69258750/91/3/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-05-19T22:25:33.647162-07:00","date_modified":"2026-05-22T08:54:43.662863-07:00","sha1":"8b016b11f2d7071ce16b88c0818e711d91a2526f","page_count":21,"file_size":793527,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 1 of 21 Page ID\n #:1113\n\n\n\n\n EXHIBIT 3\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 2 of 21 Page ID\n #:1114\n\n\n\nFrom: Thomas Sperber\nSent: Wednesday, February 18, 2026 1:59 PM\nTo: Rebecca Temkin; Jordan.Mundell@lw.com; Jordan.Cook@lw.com;\n michele.johnson@lw.com; Kristin.Murphy@lw.com\nCc: Salvatore Graziano; Jeremy Robinson\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Outstanding Discovery Issues\n\n\nCounsel,\n\nWe write to memorialize the parties\u2019 discussion from yesterday\u2019s meet and confer. Plaintiffs reserve all rights,\nincluding on the issues set forth below.\n\nFirst, the parties discussed their dispute concerning the start-date of the relevant time period for the production of\ndocuments in response to Plaintiffs\u2019 First Set of Document Requests (the \u201cRequests\u201d). Plaintiffs explained that the\nJanuary 1, 2023 start-date set forth in the Requests was reasonable considering, among other things, that (i) the\nCourt expressly relied on facts from early 2023 in sustaining Plaintiffs\u2019 claims, and (ii) Edwards\u2019 2024 TAVR sales\ngrowth guidance was generated in 2023. Thus, 2023 documents concerning the formation of such guidance are\nindisputably relevant to Plaintiffs\u2019 claims and in particular Defendants\u2019 scienter. Defendants disagreed and\nrefused this reasonable request. The parties agreed that they are at an impasse on this issue\u2014and it is ripe for a\nmotion to compel.\n\nSecond, the parties discussed Plaintiffs\u2019 proposed list of custodians. Prior to yesterday\u2019s meeting, the agreed-\nupon custodians included Bernard Zovighian, Scott Ullem, Kristen Skelton, Robert Cook, Mark Wilterding, Larry\nWood, Daveen Chopra, and the five former employees cited in the Complaint (Ed Mendoza, Matthew Nelson,\nJonathan Piller, Ahrash Poursaid, and Stephanie Toney). During the call, we discussed Plaintiffs\u2019 request for the\naddition of Donald Bobo, individual(s) reporting to Kristen Skelton (Steve Shin, Johnny Liu, Tina Tran, and Sabrina\nCervera), and the Edwards employee holding the title \u201cCorporate Vice President, TAVR\u201d during the Class Period.\n\nYou represented that Defendants would consider and get back to us promptly as to whether they would add\nDonald Bobo and/or individual(s) reporting to Kristen Skelton. You also represented that Defendants would\ninvestigate who held the \u201cCorporate Vice President, TAVR\u201d title during the Class Period, but that you suspected\nthat it was Larry Wood.\n\nPlease provide your final position on Donald Bobo, any individuals reporting to Kristen Skelton, and the Class\nPeriod \u201cCorporate Vice President, TAVR\u201d by COB on Friday February 20.\n\nThird, the parties discussed several other outstanding discovery issues:\n\n \uf0b7 We confirmed that Defendants have thus far produced 643 documents dated December 2023.\n \uf0b7 You said Defendants need more time to produce documents for newly added custodians. We confirmed\n that we will consider any reasonable proposal on the timing for these productions once Defendants have\n collected the universe of documents for review and assessed the feasibility of timely producing responsive\n documents.\n \uf0b7 You represented that you were investigating the categories of missing documents that we identified in our\n February 9 email and would get back to us promptly.\n \uf0b7 You represented that you expected to make a second production of board materials this week.\n\n\n\n 1\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 3 of 21 Page ID\n #:1115\n \uf0b7 You represented that you would investigate whether Defendants intended to include as part of these\n productions documents associated with \u201cprivate sessions\u201d in May 2024 between the board and Zovighian\n concerning TAVR sales, and any other related private sessions\u2014as requested by Plaintiffs.\n \uf0b7 You represented that you were still working on collecting documents from non-custodial sources,\n including town hall-related files. We assume that you agree these materials must be produced and you are\n simply looking into the timing of this agreed production.\n \uf0b7 You represented that you expect to make your next production of custodial documents on Thursday,\n February 19.\n\nThank you.\n\nBest,\nTom\n\n\n\nFrom: Rebecca Temkin \nSent: Friday, February 13, 2026 2:54 PM\nTo: Jordan.Mundell@lw.com; Jordan.Cook@lw.com; michele.johnson@lw.com; Kristin.Murphy@lw.com\nCc: Salvatore Graziano ; Jeremy Robinson ; Thomas Sperber\n\nSubject: Re: Patel v. Edwards Lifesciences Corp.: Outstanding Discovery Issues\n\nCounsel:\n\nYour email is incorrect and we do not appreciate your reversals on time period and custodians. Suffice it\nto say, we disagree with the positions in your email and, absent resolution, intend to move to compel.\nPlaintiffs are available to meet and confer on Tuesday at 3:30 ET. We trust that you will be prepared on\nthat call to provide Defendants' final positions on these disputes so we can either reach a compromise\nor confirm an impasse.\n\nRegards,\n\nRebecca\n\n\n\nRebecca Temkin (she/her)\nAssociate\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Jordan.Mundell@lw.com \nSent: Friday, February 13, 2026 2:12:50 PM\nTo: Rebecca Temkin ; Jordan.Cook@lw.com ;\nmichele.johnson@lw.com ; Kristin.Murphy@lw.com \nCc: Salvatore Graziano ; Jeremy Robinson ; Thomas Sperber\n\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Outstanding Discovery Issues\n\n 2\n\f Case 8:24-cv-02221-AH-KES\n Document 91-3 Filed 03/31/26 Page 4 of 21 Page ID\n #:1116\n[This message is from an external sender]\nRebecca, Thanks for your email . Our responses ar e below. We are av ailable to m eet and c onfer on thes e and a ny other issues on Tuesday betwee n 9:30-11 or 12 :3 0-2 PT. Time Period. T o start, we are confused by your claim that there are \u201cgaps\u201d in our productions \u201cwith no docum\n\n\n\n\nCGBANNERINDICATOR\n\n\n\n\nRebecca,\n\nThanks for your email. Our responses are below. We are available to meet and confer on these and any other issues on\nTuesday between 9:30-11 or 12:30-2 PT.\n\nTime Period. To start, we are confused by your claim that there are \u201cgaps\u201d in our productions \u201cwith no documents at all\ndating from January-August, October, or December 2023.\u201d We never agreed to produce documents earlier than\nDecember 2023. In our responses to your document requests, we made clear we would agree to produce responsive\ndocuments for the period, December 1, 2023 through August 31, 2024. And we have produced documents from\nDecember 2023\u2014of the thousands of documents we\u2019ve produced to date, approximately 660 are from that month\nalone. If you are having trouble locating these documents, we are happy to provide bates numbers for your reference.\n\nAs for the other categories of documents you suggest are \u201cmissing,\u201d we are looking into this and will get back to you\nshortly.\n\nCustodians. We are also surprised by your late and unreasonably burdensome request that we add more than a dozen\ncustodians to the ten we\u2019ve already agreed to. Indeed, for this first phase of discovery \u201climited to Zovighian\u2019s\nknowledge and scienter,\u201d we have already agreed to collect, review, and produce documents from the custodial files of\nthe CEO (Zovighian), CFO (Ullem), SVP of Global Finance (Wilterding), SVP of TAVR Sales (Skelton), Director of Finance\n(Cook), and the FEs, which results in a review universe of over 44,000 documents. Nevertheless, with just six weeks left\nto complete document productions and despite possessing Edwards\u2019 Workday charts since December last year, you now\ndemand that we add eight more individuals across TMTT, Strategy, and Inventory plus all employees who reported to\nZovighian, Ullem, and Chopra plus all employees \u201cresponsible for drafting meeting minutes, agendas, presentations or\nnotes\u201d for every TAVR meeting. Your demand for custodians with little or no relevance to the claims and defenses or\nwho are unlikely to possess non-duplicative responsive documents in this first phase is counterproductive. For example,\nSabrina Cervera worked in inventory and sat multiple levels below Zovighian and is unlikely to have ever interacted with\nhim personally; Steve Shin, Johnny Liu, and Tina Tran all report up to Kristen Skelton, who is already a custodian. And\nDon Bobo is not involved in TAVR sales. We do not agree to include these individuals.\n\nAs a matter of good faith, however, we will agree to add Chopra, who we had discussed previously, and are willing to\nagree to add Wood, too\u2014but for both, given the late-stage at which we will add these custodians, we expect plaintiffs to\nagree to an extended schedule to complete these two individuals\u2019 custodial productions. We suggest April 13. Please\nconfirm your agreement.\n\nZovighian\u2019s Custodial Data. We have substantially completed production of Zovighian\u2019s responsive custodial data and\nare lining up the small number of responsive documents remaining for production. We will confirm once his\nproductions are completed.\n\nBoard Materials. We have repeatedly explained to you that we produced all board materials and minutes for any\nmeeting that discussed TAVR\u2014and any materials we did not produce were because they did not involve any discussion\nof TAVR. We also explained to you that we were collecting any additional materials dating back to December 1, 2023\nand for any responsive materials, we will produce them. We are lining up that production shortly.\n\nNon-Custodial Files. We have already produced or are in the process of producing two of the categories of non-custodial\ndocuments you have requested, including board minutes and materials that discuss TAVR sales, growth, or capacity. As\nfor the other two categories, we are working with the client to identify, collect, and review these documents. If they are\nresponsive, we will produce them.\n\n\n 3\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 5 of 21 Page ID\n #:1117\nWe reserve all rights.\n\nJordan\n\nFrom: Mundell, Jordan (Bay Area)\nSent: Thursday, February 12, 2026 10:22 AM\nTo: 'Rebecca Temkin' ; Cook, Jordan (OC) ; Johnson, Michele\n(OC) ; Murphy, Kristin (OC) \nCc: Salvatore Graziano ; Jeremy Robinson ; Thomas Sperber\n\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Outstanding Discovery Issues\n\nRebecca, we\u2019re working through your requests and hope to respond to each in full tomorrow.\n\nJordan\n\nFrom: Rebecca Temkin \nSent: Thursday, February 12, 2026 7:50 AM\nTo: Mundell, Jordan (Bay Area) ; Cook, Jordan (OC) ; Johnson,\nMichele (OC) ; Murphy, Kristin (OC) \nCc: Salvatore Graziano ; Jeremy Robinson ; Thomas Sperber\n\nSubject: Patel v. Edwards Lifesciences Corp.: Outstanding Discovery Issues\n\nCounsel,\n\nFollowing up on our email from several days ago, Defendants did not respond to our request for a meet\nand confer. We would appreciate the courtesy of a prompt reply.\n\nPlaintiff's updated list of proposed additional custodians is as follows:\n 1. Daveen Chopra, Corporate Vice President, TMTT\n 2. Larry L. Wood, Corporate Vice President and Group President of TAVR and Surgical Structural\n Heart Therapies\n 3. Donald E. Bobo, Jr. Corporate Vice President, Strategy & Corporate Development\n 4. Steve Shin, VP Sales Strategy & Ops\n 5. Johnny Liu, Sr Dir, Sales Strategy and Ops\n 6. Tina Tran, Dir, Sales Strategy & Ops\n 7. Sabrina Cervera, Sr Mgr, Customer Inventory\n 8. Donald E. Bobo, Jr. Corporate Vice President, Strategy & Corporate Development.\n 9. The individual who held the title \u201cCorporate Vice President, TAVR\u201d during the Class Period.\n 10. Edwards employees who directly reported/currently report to Zovighian, Scott, Ullem, and Chopra\n regarding TAVR during the Relevant Period.\n 11. Current or former Edwards employees responsible for drafting meeting minutes, agendas,\n presentations or notes for any Town Hall or other internal Edwards meeting concerning TAVR\n growth, sales, guidance, and/or TAVR capacity (or lack thereof) during the Relevant Period.\n\nThank you,\nRebecca\n\n\n 4\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 6 of 21 Page ID\n #:1118\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Rebecca Temkin\nSent: Monday, February 9, 2026 4:37 PM\nTo: Jordan.Mundell@lw.com ; Thomas Sperber ;\nJordan.Cook@lw.com ; Jeremy Robinson ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nCounsel,\n\nThank you for your recent productions. Our review is ongoing. We write regarding several outstanding discovery\nissues. Please kindly provide your availability to meet and confer on these topics on February 10 or 11.\n\nZovighian\u2019s Custodial Files \u2013 Thank you for sending us another production of Zovighian\u2019s custodial files. How many\nmore of Zovighian\u2019s custodial documents do you expect to produce? When can we expect those documents?\n\nMissing Documents \u2013 Plaintiffs have identified the following gaps in Defendants\u2019 production to-date:\n \uf0b7 Strategic Modeling Plans for 2023 & 2024: Defendants produced a document containing \u201cEdwards 2025\n Strategic Modeling\u201d plan. E.g., EDWARDS0004103. However, we are unable to locate the equivalent\n strategic modeling plans for 2023 or 2024.\n \uf0b7 U.S. Daily Net Sales Reports: Defendants have produced multiple documents reflecting daily European net\n sales reports. E.g., EDWARDS0021811; EDWARDS0023324. However, we have not been able to locate a\n single daily net sales report for the United States.\n \uf0b7 Total Daily Net Sales Reports: Defendants produced one document reflecting the daily \u201ctotal global\u201d net\n sales report from a single in November 2023. See EDWARDS0005206. We have not been able to locate the\n rest of these documents for the relevant period.\n \uf0b7 Production Time Gaps: There are a dearth of documents dating from 2023 in Defendants\u2019 existing\n production. Indeed, we have only been able to locate a total of 12 documents dating from 2023\u2014with no\n documents at all dating from January-August, October, or December 2023.\n \uf0b7 Basis for Hospital Capacity: We have not located any documents regarding Edwards\u2019 internal tracking of\n hospital capacity during the relevant time period.\n\nPlease promptly produce the missing materials and/or remedy these production gaps.\n\nAgreed Custodians & Search Terms - Thank you for agreeing to search the custodial files of the following Edwards\npersonnel for responsive documents: Robert Cook, Ed Mendoza, Matthew Nelson, Jonathan Piller, Ahrash\nPoursaid, Kristen Skelton, Stephanie Toney, Scott Ullem, and Mark Wilterding.\nPlease confirm you will begin producing documents for these custodians promptly using the search terms that\nPlaintiffs proposed on November 12, 2025\u2014and which we understand that Defendants have agreed to at this\npoint.\n\nAdditional Custodians: Please kindly let us know Defendants\u2019 position regarding adding the below custodians:\n 1. Daveen Chopra, Corporate Vice President, TMTT\n 5\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 7 of 21 Page ID\n #:1119\n 2. Larry L. Wood, Corporate Vice President and Group President of TAVR and Surgical Structural Heart\n Therapies\n 3. Steve Shin, VP Sales Strategy & Ops\n 4. Johnny Liu, Sr Dir, Sales Strategy and Ops\n 5. Tina Tran, Dir, Sales Strategy & Ops\n 6. Sabrina Cervera, Sr Mgr, Customer Inventory\n 7. Donald E. Bobo, Jr. Corporate Vice President, Strategy & Corporate Development.\n 8. The individual who held the title \u201cCorporate Vice President, TAVR\u201d during the Class Period.\n 9. Edwards employees who directly reported/currently report to Zovighian, Scott, Ullem, and Chopra\n regarding TAVR during the Relevant Period.\n 10. Current or former Edwards employees responsible for drafting meeting minutes, agendas, presentations or\n notes for any Town Hall or other internal Edwards meeting concerning TAVR growth, sales, guidance,\n and/or TAVR capacity (or lack thereof) during the Relevant Period.\nBoard Materials \u2013 Defendants stated that they would produce a second set of Edwards board materials several\nweeks ago\u2014but did not do so. Please kindly provide these materials.\n\nRelatedly, we need to understand the scope of Defendants\u2019 production of board materials. Are Defendants\nintending to produce a full set of board materials for the Relevant Period? If not, what are Defendants producing\nand what review/production criteria are Defendants applying? Plaintiffs need to know what you are producing and,\nequally important, what Defendants are withholding. To be clear, we expect the board materials you produce to\ninclude any documents or communications concerning any \u201cprivate sessions with the board\u201d and Defendant\nZovighian, or any other executive officer, concerning TAVR sales, TAVR growth, or TAVR capacity. See e.g.,\nEDWARDS0022474.\n\nNon-custodial files \u2013 Plaintiffs have requested that Defendants produce documents from the non-custodial\nsources set forth below.\n \uf0b7 Shared/common network files concerning TAVR sales and/or projections during the Relevant Period\n \uf0b7 Board of Directors meeting files concerning TAVR sales and/or projections during the Relevant Period\n (including any related minutes, agendas, written presentations, notes, materials, correspondence etc)\n \uf0b7 Any Board of Directors\u2019 committee meeting files concerning TAVR sales and/or projections during the\n Relevant Period (including any related minutes, agendas, written presentations, notes, materials,\n correspondence etc)\n \uf0b7 Town Hall-related files concerning TAVR sales and/or projections during the Relevant Period (including any\n related minutes, agendas, written presentations, notes, materials, correspondence etc)\n\nPlease kindly let us know whether Defendants agree to do so\u2014or confirm that the parties are at an impasse.\n\nPlaintiffs reserve all rights, including to request additional custodians, search terms, or sources.\n\nRegards,\nRebecca\n\nFrom: Jordan.Mundell@lw.com \nSent: Monday, January 12, 2026 3:08 PM\nTo: Rebecca Temkin ; Thomas Sperber ;\nJordan.Cook@lw.com; Jeremy Robinson ; Salvatore Graziano \nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nRebecca, we are available tomorrow between 10-11 PT or after 2:30 PT. Let us know if that works for you.\n 6\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 8 of 21 Page ID\n #:1120\n\nJordan\n\nFrom: Rebecca Temkin \nSent: Monday, January 12, 2026 7:49 AM\nTo: Mundell, Jordan (Bay Area) ; Thomas Sperber ; Cook,\nJordan (OC) ; Jeremy Robinson ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nCounsel,\n\nFollowing up on the below. Please let us know your availability to meet and confer either today or\ntomorrow.\n\nThanks,\nRebecca\n\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Rebecca Temkin \nSent: Monday, January 5, 2026 1:12 PM\nTo: Jordan.Mundell@lw.com ; Thomas Sperber ;\nJordan.Cook@lw.com ; Jeremy Robinson ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nHi Jordan M. and Jordan C.,\n\nThank you for delivering the hard-copy of our 26(f) report to the Court on Friday. Was a cover letter sent to\nthe judge for the hard copies? If so, please send that and please copy Plaintiffs' counsel on all future\ncorrespondence to the court relating to this case. During our meet and confer last week, we agreed to\nmeet again on Friday, January 9 to discuss outstanding discovery issues. Please let us know your\navailability that day.\n\nAdditionally, you represented last week that Defendants would make a production by early this week\nincluding Zovighian\u2019s custodial documents. Do you have an update on the timing of that production?\n\nRegards,\nRebecca\n\n 7\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 9 of 21 Page ID\n #:1121\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Jordan.Mundell@lw.com \nSent: Sunday, December 14, 2025 10:44 PM\nTo: Thomas Sperber ; Jordan.Cook@lw.com ; Rebecca Temkin\n; Jeremy Robinson ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nHi all,\n\nI hope you had a nice weekend. Attached is a hit report for Zovighian, Ullem, and Wilterding, applying plaintiffs\u2019 search\nterms. As noted, while we reserve all rights with respect to the search parameters, we are reviewing documents within\nthis set and will produce responsive, non-privileged documents on a rolling basis. We expect to share screenshots\nshowing Edwards\u2019 organizational structure this week and will follow up shortly with timing on the production of the\nadditional Board materials that we discussed.\n\nJordan\n\nFrom: Thomas Sperber \nSent: Monday, December 1, 2025 9:42 AM\nTo: Cook, Jordan (OC) ; Rebecca Temkin ; Jeremy Robinson\n; Salvatore Graziano ; Mundell, Jordan (Bay Area)\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nThanks Jordan. 4pm ET tomorrow works for us. I\u2019ll update the invite.\n\nFrom: Jordan.Cook@lw.com \nSent: Monday, December 1, 2025 12:39 PM\nTo: Thomas Sperber ; Rebecca Temkin ; Jeremy\nRobinson ; Salvatore Graziano ; Jordan.Mundell@lw.com\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nHi Tom,\n\n\n\n\n 8\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 10 of 21 Page\n ID #:1122\nThanks for checking in. Given some scheduling challenges with the holiday, we are currently slated to continue\ndiscussions about custodians with our client tomorrow morning. To the extent you are available, it might make\nsense to schedule our call for the afternoon tomorrow ET \u2013 does 4 p.m. work for your team?\n\nThanks,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Thomas Sperber \nSent: Monday, December 1, 2025 8:11 AM\nTo: Cook, Jordan (OC) ; Rebecca Temkin ; Jeremy Robinson\n; Salvatore Graziano ; Mundell, Jordan (Bay Area)\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nCounsel,\n\nWe hope you had a relaxing Thanksgiving. Are you still available for a call today? And were you able to gain\nadditional information and clarity from your client to inform our document custodian negotiations?\n\nThanks,\nTom\n\nFrom: Thomas Sperber\nSent: Tuesday, November 25, 2025 2:12 PM\nTo: 'Jordan.Cook@lw.com' ; Rebecca Temkin ; Jeremy\nRobinson ; Salvatore Graziano ; Jordan.Mundell@lw.com\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nGreat, thanks Jordan. I moved the invite to 2pm Monday for now just to get it back on the calendar, but happy to\nmove it to within a window that works for everyone.\n\nFrom: Jordan.Cook@lw.com \nSent: Tuesday, November 25, 2025 2:10 PM\nTo: Thomas Sperber ; Rebecca Temkin ; Jeremy\nRobinson ; Salvatore Graziano ; Jordan.Mundell@lw.com\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nThanks very much - I appreciate it. Monday works, will revert back with available windows.\n\n\n 9\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 11 of 21 Page\n ID #:1123\n\nFrom: Thomas Sperber \nSent: Tuesday, November 25, 2025 9:53:27 AM\nTo: Jordan.Cook@lw.com ; Rebecca Temkin ; Jeremy Robinson\n; Salvatore Graziano ; Jordan.Mundell@lw.com\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nHey Jordan,\n\nThanks for letting us know, totally understood. Sorry to hear about the delays, hopefully all smooth sailing from\nhere!\n\nTomorrow doesn\u2019t work for us, and the rest of the week is also pretty tight with travel etc\u2026 Can we plan to talk on\nMonday? Hopefully that will give your team more time to get some clarity on the custodians counter-proposal.\n\nBest,\nTom\n\nFrom: Jordan.Cook@lw.com \nSent: Tuesday, November 25, 2025 12:34 PM\nTo: Thomas Sperber ; Rebecca Temkin ; Jeremy\nRobinson ; Salvatore Graziano ; Jordan.Mundell@lw.com\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nHi Tom and Team,\n\nUnfortunately I have been stuck on a runway this morning for an hour and a half with \u201cmechanical\nissues\u201d and just got an update that it\u2019s going to be at least another 30 minutes. As a result, I\u2019m going to\nmiss our call.\n\nIs there a time we could reschedule tomorrow? I can be flexible on timing. Apologies for the\ninconvenience.\n\nThanks,\n\nJordan\n\nFrom: Cook, Jordan (OC) \nSent: Monday, November 24, 2025 12:10:49 PM\nTo: Thomas Sperber ; Rebecca Temkin ; Mundell,\nJordan (Bay Area) ; Jeremy Robinson ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nThanks, Tom \u2013 we\u2019ll take a look.\n 10\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 12 of 21 Page\n ID #:1124\n\nOn discovery, this week is a little tricky just with the holiday and travel. We can be available tomorrow late\nafternoon ET (say, 4:30) for half an hour or Wednesday morning PT.\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Thomas Sperber \nSent: Monday, November 24, 2025 9:07 AM\nTo: Cook, Jordan (OC) ; Rebecca Temkin ; Mundell, Jordan (Bay\nArea) ; Jeremy Robinson ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nCounsel,\n\nWe agree to the revisions to the schedule you requested. Attached is a streamlined document setting out the\nagreed-upon deadlines and accepting your revisions circulated on Friday\u2014the only other changes are to remove\nthe columns setting forth the parties\u2019 previous proposals.\n\nDo please let us know if you are available later today or tomorrow to confer on discovery.\n\nThanks,\nTom\n\nFrom: Thomas Sperber\nSent: Friday, November 21, 2025 12:37 PM\nTo: 'Jordan.Cook@lw.com' ; Rebecca Temkin ;\nJordan.Mundell@lw.com; Jeremy Robinson ; Salvatore Graziano \nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nJordan,\n\nThank you for the hit report, your revisions to the schedule, and the update on your proposal regarding custodians.\nWe are considering your schedule revisions and will get back to you soon. In the meantime, can we schedule a call\non Monday or Tuesday next week to discuss?\n\nThanks,\nTom\n\nFrom: Jordan.Cook@lw.com \nSent: Friday, November 21, 2025 11:58 AM\nTo: Rebecca Temkin ; Jordan.Mundell@lw.com; Jeremy Robinson\n; Thomas Sperber ; Salvatore Graziano\n\n\n\n 11\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 13 of 21 Page\n ID #:1125\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nRebecca,\n\nThanks for the follow up. As I mentioned on our call, we are working with our client to obtain additional\ninformation that will better assist with our custodial negotiations. Unfortunately, as discussed, they do not\nmaintain historical org charts in the ordinary course, but we are trying to find a solution. We are still working on\nthat with the client, so need a few more days before we are ready to send a counterproposal.\n\nIn the meantime, we are providing a hit report for Plaintiffs\u2019 search terms over Mr. Zovighian\u2019s data. While we\ncannot agree at this point to the search terms over unknown custodial data, we can agree to apply Plaintiffs\u2019 terms\nand are working to review the hits for Mr. Zovighian. To keep things moving along, we have also collected data for\nScott Ulem, Mark Wilterding, and the FEs (to the extent the Company still has data for those FEs) and will send hit\nreports for those custodians, as well. Defendants reserve all rights with respect to the proposed search terms,\nincluding to further negotiate them if the hit reports from other custodians\u2019 data proves to be unduly burdensome,\ndisproportionate to the needs of the case, and/or inappropriate for Phase 1 discovery.\n\nI am also providing a marked-up schedule here. While we can agree to most of the dates, as mentioned on our\ncall, we had a few further revisions. We are happy to discuss this and, as discussed, reserve rights to revisit these\ndates (and in particular, the substantial completion deadline) depending on the outcome of the parties\u2019 custodial\nnegotiations.\n\nLet me know if you have any questions \u2013 otherwise, we will propose times early next week for a further conference.\n\nThanks,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Rebecca Temkin \nSent: Thursday, November 20, 2025 6:58 AM\nTo: Mundell, Jordan (Bay Area) ; Jeremy Robinson ; Cook, Jordan\n(OC) ; Thomas Sperber ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nHi Jordan,\n\nFollowing up on Monday's discussion regarding the case schedule and discovery issues. You said you\nwould send some proposals today. Can we schedule a call for tomorrow to discuss?\n\nLet us know when works,\nRebecca\n 12\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 14 of 21 Page\n ID #:1126\n\n\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Rebecca Temkin \nSent: Friday, November 14, 2025 3:24 PM\nTo: Jordan.Mundell@lw.com ; Jeremy Robinson ;\nJordan.Cook@lw.com ; Thomas Sperber ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nSame to you!\n\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Jordan.Mundell@lw.com \nSent: Friday, November 14, 2025 3:22 PM\nTo: Rebecca Temkin ; Jeremy Robinson ; Jordan.Cook@lw.com\n; Thomas Sperber ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nThanks, Rebecca. Let\u2019s speak at 3 ET on Monday. Have a nice weekend.\n\nJordan\n\nFrom: Rebecca Temkin \nSent: Friday, November 14, 2025 11:44 AM\nTo: Mundell, Jordan (Bay Area) ; Jeremy Robinson ; Cook, Jordan\n(OC) ; Thomas Sperber ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n 13\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 15 of 21 Page\n ID #:1127\nThanks Jordan,\n\nWe are available to meet and confer on Monday from 1-2pm, or 3-5pm EST.\n\nLet us know if that works for you.\n\nRegards,\nRebecca\n\n\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Jordan.Mundell@lw.com \nSent: Thursday, November 13, 2025 6:34 PM\nTo: Rebecca Temkin ; Jeremy Robinson ; Jordan.Cook@lw.com\n; Thomas Sperber ; Salvatore Graziano\n\nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nHi Rebecca, following up with responses to your proposed list of custodians. As you know, the Court suggested phased\ndiscovery targeting \u201cthe issue of Zovighian\u2019s knowledge and scienter,\u201d yet your list below extends well beyond that\ndiscrete issue. For instance, you included anyone \u201cresponsible for drafting meeting minutes, agendas, presentations, or\nnotes\u201d for a host of internal meetings, including meetings Zovighian likely did not attend. We\u2019re unsure what relevant\ninformation the person drafting those meeting minutes would possess\u2014particularly when you\u2019ve also requested the\nminutes and materials for those meetings. We\u2019re also confused by your inclusion of each of Edwards\u2019 board members as\ncustodians given this case concerns projections prepared at the management-level.\n\nAs you\u2019ll see from our proposed list below, we included those individuals most likely to possess relevant information\nregarding the discrete issue the Court reserved for phase 1 discovery, including Zovighian himself; Scott Ullem, who\nserved as CFO; and Mark Wilterding, Edwards\u2019 SVP of Global Finance, who served as SVP in IR and FP&A during the\nrelevant period. We\u2019ve also included the FEs, to the extent we still possess their custodial data, given the Court\u2019s\nreliance on allegations attributed to them in its motion to dismiss order.\n\nWe\u2019re happy to meet and confer on custodians and can be available to discuss tomorrow or early next week. We also\nhad a few questions regarding your latest edits to the proposed case schedule, which we can discuss on that call,\ntoo. Let us know what works for you.\n\n**\nDefendants\u2019 List of Custodians:\n 1. Bernard Zovighian;\n 2. Scott Ullem;\n 14\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 16 of 21 Page\n ID #:1128\n 3. Mark Wilterding;\n 4. FE1;\n 5. FE2;\n 6. FE3;\n 7. FE4; and\n 8. FE5.\n\nSearch Terms: We are assessing your proposed search terms and will share any edits shortly.\n\nJordan\n\nFrom: Mundell, Jordan (Bay Area)\nSent: Wednesday, November 12, 2025 4:34 PM\nTo: 'Rebecca Temkin' ; Jeremy Robinson ; Cook, Jordan (OC)\n; Thomas Sperber ; Salvatore Graziano\n\nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nRebecca,\n\nThanks for sharing your proposed list of custodians and search terms. We\u2019re considering and will get back to you shortly\nwith our response, as well as any additional edits to the case schedule you circulated last week. And yes, confirming\nthat we agree to exchange initial disclosures tomorrow.\n\nJordan\n\nFrom: Rebecca Temkin \nSent: Wednesday, November 12, 2025 1:02 PM\nTo: Jeremy Robinson ; Cook, Jordan (OC) ; Thomas Sperber\n; Salvatore Graziano \nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) ; Mundell,\nJordan (Bay Area) \nSubject: Re: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nCounsel,\n\nWe look forward to Defendants\u2019 prompt response to our November 6 proposal on the schedule, which\naccepts many of the dates proposed by Defendants and otherwise attempts to find middle ground to\nreach a compromise. Also on November 6, to move things forward in what has been a lengthy process,\nwe proposed that the Parties exchange initial disclosures tomorrow, November 13. Please confirm by\nclose of business today that Defendants agree to exchange initial disclosures tomorrow.\n\nAlso, as flagged in multiple separate emails, Defendants made a small production on Monday\u2014but did\nnot provide the password for it until 2:30pm EST today. As such, we have only just gained access the\nproduction.\n\nThe current agreed deadline to reach an agreement on custodians and search terms for Phase One\ndiscovery is on Friday, November 14. Do Defendants still want to proceed with phased discovery? If so,\nwe would have expected to receive a proposal on custodians and search terms by now from\n 15\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 17 of 21 Page\n ID #:1129\nDefendants. To state the obvious, Plaintiffs are at a significant informational disadvantage compared to\nDefendants.\n\nNevertheless, in an effort to move things forward, Plaintiffs set forth below an initial proposal regarding\nPhase 1 custodians/custodial sources and search terms to get the ball rolling. We anticipate adding\nadditional custodians or terms\u2014so we offer the below as a first step in this process and to get discovery\nunderway.\n\nInitial custodians (including all personal devices, messaging applications, personal and professional\nemail accounts, social media accounts, shared or personal drives), and custodial sources:\n\n 1. Bernard J. Zovighian\n 2. Larry L. Wood\n 3. Scott B. Ullem\n 4. Daveen Chopra\n 5. Nicholas J. Valeriani\n 6. Leslie C. Davis\n 7. David T. Feinberg\n 8. Kieran T. Gallahue\n 9. Leslie S. Heisz\n 10. Paul A. LaViolette\n 11. Steven R. Loranger\n 12. Ramona Sequeira\n 13. Current or former Edwards employees who directly reported to Defendant\n Zovighian during the period from January 1, 2023 through February 28, 2025 (the \u201cRelevant\n Period\u201d).\n 14. Current or former Edwards employees who regularly met with Defendant Zovighian concerning\n Edwards\u2019 TAVR products during the Relevant Period.\n 6. Current or former Edwards employees responsible for evaluating metrics or data concerning TAVR\n sales and/or procedure volumes during the Relevant Period.\n 7. Current or former Edwards employees responsible for drafting meeting minutes, agendas,\n presentations or notes for any Town Hall or other internal Edwards meeting concerning TAVR\n growth, sales, guidance, and/or TAVR capacity (or lack thereof) during the Relevant Period.\n 8. Additional custodial sources:\n o Shared/common network files concerning TAVR sales and/or projections during the\n Relevant Period\n o Board of Directors meeting files concerning TAVR sales and/or projections during the\n Relevant Period (including any related minutes, agendas, written presentations, notes,\n materials, correspondence etc)\n o Any Board of Directors\u2019 committee meeting files concerning TAVR sales and/or projections\n during the Relevant Period (including any related minutes, agendas, written presentations,\n notes, materials, correspondence etc)\n o Town Hall-related files concerning TAVR sales and/or projections during the Relevant\n Period (including any related minutes, agendas, written presentations, notes, materials,\n correspondence etc)\n\nInitial search terms:\n\n 16\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 18 of 21 Page\n ID #:1130\n \uf0b7 TAVR AND (grow* OR sales OR volume OR figure* OR number* OR capacity OR bandwidth OR\n constrain* OR tax* OR pressure OR revenue OR project* OR focus OR salesforce OR data OR\n decrease OR decel* OR declin* OR plateau OR stagnat* OR drop-off OR fall OR lower OR \u201c8%-\n 10%\u201d OR \u201c8-10%\u201d OR \u201c8 to 10%\u201d OR \u201c8% to 10%\u201d OR 6% OR \u201c5%-7%\u201d OR \u201c5-7%\u201d OR \u201c5% to 7%\u201d\n OR \u201c5 to 7%\u201d OR JenaValve OR Endotronix OR Innovalve OR acqui* OR compet*)\n \uf0b7 (PASQUAL OR EVOQUE OR TMTT) AND TAVR AND (capacity OR constrain* OR tax* OR pressure)\n \uf0b7 (Zovighian OR Bernard) AND (8,617 OR ((sale OR sell* OR sold) /15 (stock OR shares OR insider)))\n \uf0b7 (healthcare OR hospital OR center OR transcatheter) AND (capacity OR bandwidth)\n\nPlaintiffs reserve all rights, including to revise, amend or supplement any of the proposed custodians or\nsearch terms set forth above.\n\nPlease confirm that Defendants agree to exchange initial disclosures on November 13, 2025 and let us\nknow if Defendants have any additional custodians or search terms in mind.\n\nWe are immediately available to meet and confer regarding the above.\n\nRegards,\nRebecca\n\n\nRebecca Temkin (she/her)\nAssociate\n\n1251 Avenue of the Americas\nNew York, NY 10020\nOffice: (212) 554-1588\n\n\nFrom: Jeremy Robinson \nSent: Thursday, November 6, 2025 11:51 AM\nTo: Jordan.Cook@lw.com ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \nCc: michele.johnson@lw.com ; Kristin.Murphy@lw.com ;\nJordan.Mundell@lw.com \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nJordan and team: Thank you again for the call earlier this week. Attached is a further proposal\nalong the lines we discussed in clean and redline (against your last version). Please kindly let\nus know if this works for Defendants. Leaving all other issues aside, we think the parties\nshould plan to exchange initial disclosures on November 13. Otherwise, we continue to reserve\nrights. Thank you.\n\nBest,\nJeremy\n\n___________________\nJeremy P. Robinson\n 17\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 19 of 21 Page\n ID #:1131\nBLB&G LLP\nOffice: 212.554.1492\nMobile: 646.708.0507\n\nFrom: Jordan.Cook@lw.com \nSent: Thursday, October 30, 2025 12:49 PM\nTo: Jeremy Robinson ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com; Jordan.Mundell@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nThanks, Jeremy. We are available Monday from 9-9:30, 10-11, or 12-1 (all PT) if there is a window that works for\nyou.\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Jeremy Robinson \nSent: Thursday, October 30, 2025 7:41 AM\nTo: Cook, Jordan (OC) ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) ; Mundell,\nJordan (Bay Area) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nJordan: Thank you for your email. While we continue to consider Defendants\u2019 counterproposal,\nwe agree that it makes sense to get a call on schedule.\n\nWhat timing works for Defendants tomorrow or Monday?\n\nBest,\nJeremy\n\n___________________\nJeremy P. Robinson\nBLB&G LLP\nOffice: 212.554.1492\nMobile: 646.708.0507\n\nFrom: Jordan.Cook@lw.com \nSent: Tuesday, October 28, 2025 9:18 AM\nTo: Jeremy Robinson ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \n\n\n 18\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 20 of 21 Page\n ID #:1132\nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com; Jordan.Mundell@lw.com\nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nJeremy,\n\nThank you for these revisions \u2013 attached are some further revisions from Defendants. We would suggest at this\npoint that if there are still areas of disagreement, we hop on the phone to discuss to see if we can better\nunderstand your position and come to an agreement. Defendants too reserve all rights.\n\nPlease let us know your thoughts when you are able. Happy to find time to discuss as needed.\n\nThanks,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Jeremy Robinson \nSent: Thursday, October 16, 2025 11:06 AM\nTo: Cook, Jordan (OC) ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \nCc: Johnson, Michele (OC) ; Murphy, Kristin (OC) ; Mundell,\nJordan (Bay Area) \nSubject: RE: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\nPlease see the attached revised draft case schedule. Notwithstanding our general disagreement\nwith Defendants\u2019 proposed approach, we have made a good faith attempt to reach a compromise\nhere. We reserve all rights regarding these issues, including to revert to Plaintiffs\u2019 original\nposition on the case schedule and discovery to the extent that an agreement cannot be reached.\n\nWe look forward to Defendants\u2019 prompt response. Please let us know if a call would be helpful.\nThank you.\n\nBest,\nJeremy\n\n___________________\nJeremy P. Robinson\nBLB&G LLP\nOffice: 212.554.1492\nMobile: 646.708.0507\n\n\n\n 19\n\f Case 8:24-cv-02221-AH-KES Document 91-3 Filed 03/31/26 Page 21 of 21 Page\n ID #:1133\nFrom: Jordan.Cook@lw.com \nSent: Friday, October 10, 2025 6:21 PM\nTo: Jeremy Robinson ; Rebecca Temkin ; Thomas Sperber\n; Salvatore Graziano \nCc: michele.johnson@lw.com; Kristin.Murphy@lw.com; Jordan.Mundell@lw.com\nSubject: Patel v. Edwards Lifesciences Corp.: Draft Schedule\n\n[This message is from an external sender]\n\nJeremy and Team,\n\nPlease see attached for a revised proposed schedule. This remains subject to client review but wanted to send it\nover in the interest of time and for discussion.\n\nHave a good weekend,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive\n20th Floor\nCosta Mesa, CA 92626-1925\nDirect Dial: +1.714.755.8238\nEmail: jordan.cook@lw.com\nhttps://www.lw.com\n\n_________________________________\n\nThis email may contain material that is confidential, privileged and/or attorney work product for the sole use of\nthe intended recipient. Any review, disclosure, reliance or distribution by others or forwarding without express\npermission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all\ncopies including any attachments.\n\nLatham & Watkins LLP or any of its affiliates may monitor electronic communications sent or received by our\nnetworks in order to protect our business and verify compliance with our policies and relevant legal\nrequirements. Any personal information contained or referred to within this electronic communication will be\nprocessed in accordance with the firm's privacy notices and Global Privacy Standards available at www.lw.com.\n\n\n\n\n 20\n\f","ocr_status":1,"date_upload":"2026-05-19T22:26:12.227094-07:00","document_number":"91","attachment_number":3,"pacer_doc_id":"031047376927","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 3","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479806725/","id":479806725,"tags":[],"absolute_url":"/docket/69258750/91/4/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-05-19T22:25:33.660292-07:00","date_modified":"2026-05-22T08:52:59.142185-07:00","sha1":"560ac272a15373709f746a627079917051dc72f4","page_count":4,"file_size":370893,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.91.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 8:24-cv-02221-AH-KES Document 91-4 Filed 03/31/26 Page 1 of 4 Page ID\n #:1134\n\n\n\n\n EXHIBIT 4\n\f Case 8:24-cv-02221-AH-KES Document 91-4 Filed 03/31/26 Page 2 of 4 Page ID\n #:1135\n\n\n\nFrom: Thomas Sperber\nSent: Sunday, March 8, 2026 1:18 PM\nTo: Jordan.Cook@lw.com; Jeremy Robinson; Rebecca Temkin\nCc: Salvatore Graziano; michele.johnson@lw.com; Kristin.Murphy@lw.com;\n Jordan.Mundell@lw.com; Kathy.Bruce@lw.com\nSubject: Re: Edwards Securities Litigation: Document Production Deadline\n\n\n\nThanks Jordan, we are available at 2:30, but may need more than 30 minutes. Will send a dial-in.\n\nFrom: Jordan.Cook@lw.com \nSent: Friday, March 6, 2026 4:20 PM\nTo: Thomas Sperber ; Jeremy Robinson ; Rebecca\nTemkin \nCc: Salvatore Graziano ; michele.johnson@lw.com ;\nKristin.Murphy@lw.com ; Jordan.Mundell@lw.com ;\nKathy.Bruce@lw.com \nSubject: RE: Edwards Securities Litigation: Document Production Deadline\n\n[This message is from an external sender]\n\n To help\n protect y our\n priv acy,\n Micro so ft\n Office\n prev ented\n auto matic\n download of\n this pictu re\n from the\n In ternet.\n\n\n\n\nTom,\n\nAs discussed, attached is a draft protective order. Please let us know if it would be helpful to discuss on our meet\nand confer next week. We are available Tuesday between 1-2 E ET or 2:30-3 ET.\n\nThanks,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Thomas Sperber \nSent: Friday, March 6, 2026 11:10 AM\nTo: Cook, Jordan (OC) ; Jeremy Robinson ; Rebecca Temkin\n\nCc: Salvatore Graziano ; Johnson, Michele (OC) ; Murphy, Kristin\n(OC) ; Mundell, Jordan (Bay Area) ; Bruce, Kathy (SD)\n\nSubject: Re: Edwards Securities Litigation: Document Production Deadline\n\nCounsel,\n\n 1\n\f Case 8:24-cv-02221-AH-KES Document 91-4 Filed 03/31/26 Page 3 of 4 Page ID\n #:1136\nThanks for your email. On Defendants\u2019 request for two more weeks to produce Chopra and Wood\u2019s documents \u2013\nthat\u2019s fine. We note that the deadline you reference was not ordered by the Court.\n\nRelatedly, we would like to meet and confer on Monday or Tuesday, please let us know your availability. On that\nmeet and confer, please be prepared to discuss the status of Defendants\u2019 document productions, including the\nscope of your planned production the \u201c2024 strategic planning documents.\u201d\n\nWe also want to discuss on the call the subpoenas that Defendants served notice of late last night. Have\nDefendants completed their productions of documents relating to the noticed deponents? We also need to\ndiscuss the scheduling of those depositions, as the proposed dates do not work for us.\n\nFurther, Defendants stated months ago that they might be interested in negotiating a protective order\u2014and they\nwould promptly send us a draft. Given that we have not heard from Defendants on this issue since then, we\nunderstand that Defendants no longer are concerned about protecting confidentiality of discovery documents or\ntestimony. As such, among other things, we need to discuss the impact on prior confidentiality designations that\nare now moot.\n\nBest,\nTom\n\n\nFrom: Jordan.Cook@lw.com \nSent: Friday, March 6, 2026 12:32:59 PM\nTo: Jeremy Robinson ; Thomas Sperber ; Rebecca Temkin\n\nCc: Salvatore Graziano ; michele.johnson@lw.com ;\nKristin.Murphy@lw.com ; Jordan.Mundell@lw.com ;\nKathy.Bruce@lw.com \nSubject: RE: Edwards Securities Litigation: Document Production Deadline\n\n[This message is from an external sender]\n\nAll \u2013 just following up on the request below. Please let us know if you consent, otherwise we may need to seek\nleave of the court.\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive | 20th Floor | Costa Mesa, CA 92626-1925\nD: +1.714.755.8238\n\nFrom: Cook, Jordan (OC)\nSent: Wednesday, March 4, 2026 4:27 PM\nTo: Jeremy Robinson ; Thomas Sperber ; Rebecca Temkin\n\nCc: Salvatore Graziano ; Johnson, Michele (OC) ; Murphy, Kristin\n(OC) ; Mundell, Jordan (Bay Area) ; Bruce, Kathy (SD)\n\nSubject: Edwards Securities Litigation: Document Production Deadline\n\nCounsel,\n\n 2\n\f Case 8:24-cv-02221-AH-KES Document 91-4 Filed 03/31/26 Page 4 of 4 Page ID\n #:1137\nDefendants have been diligently working to produce documents responsive to Plaintiffs\u2019 RFPs within the scope of\nPhase 1 discovery. We anticipate making another production tomorrow and expect to complete our document\nproductions as to all custodians except Daveen Chopra and Larry Wood by the current document production\ncompletion deadline. However, we would appreciate confirmation that you agree to the brief two-week extension\n(to March 23, 2026) to complete the Chopra and Wood custodial documents that we previously previewed we may\nneed, as well as to produce the requested 2024 strategic planning documents, which were prepared in 2023 and\ntherefore fell outside of the date range to which Defendants agreed to perform custodial searches. Please let us\nknow if you consent to that extension. Assuming you do, we will still plan to produce a privilege log on the\ncurrently scheduled deadline but would propose producing an amended privilege log which includes documents\nfrom Mr. Chopra and Mr. Wood\u2019s custodial files two weeks after completing that production (by April 6, 2026).\n\nWe are available to discuss if helpful.\n\nBest,\n\nJordan\n\nJordan Davisson Cook\nPronouns: She/Her/Hers\n\nLATHAM & WATKINS LLP\n650 Town Center Drive\n20th Floor\nCosta Mesa, CA 92626-1925\nDirect Dial: +1.714.755.8238\nEmail: jordan.cook@lw.com\nhttps://www.lw.com\n\n_________________________________\n\nThis email may contain material that is confidential, privileged and/or attorney work product for the sole use of\nthe intended recipient. Any review, disclosure, reliance or distribution by others or forwarding without express\npermission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all\ncopies including any attachments.\n\nLatham & Watkins LLP or any of its affiliates may monitor electronic communications sent or received by our\nnetworks in order to protect our business and verify compliance with our policies and relevant legal\nrequirements. Any personal information contained or referred to within this electronic communication will be\nprocessed in accordance with the firm's privacy notices and Global Privacy Standards available at www.lw.com.\n\n\n\n\n 3\n\f","ocr_status":1,"date_upload":"2026-05-19T22:26:16.040474-07:00","document_number":"91","attachment_number":4,"pacer_doc_id":"031047376928","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit 4","acms_document_guid":""}],"date_created":"2026-03-31T09:37:11.518992-07:00","date_modified":"2026-10-03T05:48:27.990887-07:00","date_filed":"2026-03-31","time_filed":"09:10:36","entry_number":91,"recap_sequence_number":"2026-03-31.001","pacer_sequence_number":302,"description":"SUPPLEMENT to for Order 88 [Letter Brief Re: April 1, 2026 Informal Telephonic Conference] filed by Movants City of Fort Lauderdale Police & Firefighters Retirement System, Louisiana Sheriffs' Pension & Relief Fund. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Robinson, Jeremy) (Entered: 03/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/459152724/","id":459152724,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69258750/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/474171949/","id":474171949,"tags":[],"absolute_url":"/docket/69258750/92/dhimant-patel-v-edwards-lifesciences-corporation/","date_created":"2026-03-31T09:36:59.265530-07:00","date_modified":"2026-05-22T08:27:17.066471-07:00","sha1":"4902295d17f41504da28e52d9159c4fa5268a157","page_count":5,"file_size":219160,"filepath_local":"recap/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.92.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.944521/gov.uscourts.cacd.944521.92.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 8:24-cv-02221-AH-KES Document 92 Filed 03/31/26 Page 1 of 5 Page ID\n #:1138\n\n 1 LATHAM & WATKINS LLP\n Michele D. Johnson (SBN 198298)\n 2 Kristin N. Murphy (SBN 268285)\n Jordan D. Cook (SBN 293394)\n 3 650 Town Center Drive, 20th Floor\n Costa Mesa, CA 92626\n 4 Telephone: (714) 540-1235\n Email: michele.johnson@lw.com\n 5 Email: kristin.murphy@lw.com\n Email: jordan.cook@lw.com\n 6\n Attorneys for Defendants\n 7\n Edwards Lifesciences Corporation and\n 8 Bernard J. Zovighian\n 9\n [Additional counsel listed on signature page]\n 10\n 11 UNITED STATES DISTRICT COURT\n 12 CENTRAL DISTRICT OF CALIFORNIA\n\n 13\n DHIMANT PATEL, Individually and on Case No. 8:24-cv-02221-AH-KES\n 14 Behalf of All Others Similarly Situated,\n Assigned to: Hon. Anne Hwang\n 15\n Plaintiff,\n 16 v. DEFENDANTS\u2019 LETTER BRIEF\n RE: INFORMAL TELEPHONIC\n 17\n EDWARDS LIFESCIENCES CONFERENCE\n 18 CORPORATION and BERNARD J.\n ZOVIGHIAN, Hon. Karen E. Scott\n 19\n 20 Defendants. Date: March 31, 2026\n Time: 9:30 a.m.\n 21\n 22\n 23\n 24\n 25\n 26\n 27\n 28\n CASE NO. 8:24-cv-02221-AH-KES\nATTORNEYS AT LAW\n ORANGE COUNTY\n COVER PAGE TO LETTER BRIEF\n\fCase 8:24-cv-02221-AH-KES Document 92 Filed 03/31/26 Page 2 of 5 Page ID\n #:1139 505 Montgomery Street, Suite 2000\n San Francisco, California 94111-6538\n Tel: +1.415.391.0600 Fax: +1.415.395.8095\n www.lw.com\n\n FIRM / AFFILIATE OFFICES\n Austin Milan\n Beijing Munich\n Boston New York\n Brussels Orange County\n Chicago Paris\n\nMarch 31, 2026 Dubai Riyadh\n D\u00fcsseldorf San Diego\n Frankfurt San Francisco\nVIA ECF Hamburg Seoul\n Hong Kong Silicon Valley\n Houston Singapore\nHon. Karen E. Scott, Magistrate Judge London Tel Aviv\nUnited States District Court, Central District of Los Angeles Tokyo\n\nCalifornia Madrid Washington, D.C.\n\n\nCourtroom 6D (Ronald Reagan Federal Building)\n411 W. Fourth Street, Santa Ana, CA 92701\n\n Re: Patel v. Edwards Lifesciences Corp., et al, 8:24-cv-02221-AH-KES\n (C.D. Cal.)\n\nTo the Hon. Karen E. Scott, Magistrate Judge:\n\n Defendants Edwards Lifesciences Corporation and Bernard Zovighian\n(\u201cDefendants\u201d) submit this letter brief in opposition to Plaintiffs\u2019 efforts to\nunreasonably expand the responsive time period governing Defendants\u2019 document\nproductions for the first phase of discovery. For the reasons discussed below,\nDefendants respectfully request that the Court deny Plaintiffs\u2019 request.\n\nI. THE COURT INVITED PHASED DISCOVERY FOCUSED ON THE\n ISSUE OF ZOVIGHIAN\u2019S SCIENTER\n\n This is a narrow case made narrower by the Court\u2019s September 2025 ruling\non the motion to dismiss, which dismissed a number of defendants, claims, and\nchallenged statements. Dkt. 72.1 At issue are ten statements Edwards and Zovighian\nmade on just two dates, February 6 and April 25, 2024, expressing confidence in\nEdwards\u2019 FY 2024 sales guidance for its Transcatheter Aortic Valve Replacement\n(\u201cTAVR\u201d) business. That guidance\u2014announced months earlier on December 7,\n2023 and projecting year-over-year sales growth of 8-10%\u2014is not at issue. Rather,\nthe Class Period in this case\u2014which Plaintiffs selected and pled in their\n\n\n\n1\n Edwards\u2019 pre-Class Period statements announcing FY 2024 guidance were\ndismissed.\n 1\n\fCase 8:24-cv-02221-AH-KES Document 92 Filed 03/31/26 Page 3 of 5 Page ID\nMarch 31, 2026 #:1140\nPage 2\n\n\n\n\nComplaint\u2014starts on February 6, 2024 and ends on July 24, 2024, when Edwards\ninformed investors it was lowering full-year guidance.\n\n Even as to what remains, the Court said the issue of Zovighian\u2019s scienter was\na \u201cvery close one\u201d and invited \u201cphased discovery limited to the issue of Zovighian\u2019s\nknowledge,\u201d followed by \u201cearly motion practice.\u201d Id. at 21, n.10. The parties agreed\nthat Defendants would complete \u201cPhase One\u201d productions relating to this sole issue\nby March 9, 2026. See Dkt. 81 at 1. Plaintiffs first served document requests on\nSeptember 29, 2025. Defendants timely responded and agreed to produce\nresponsive documents from the period, December 1, 2023 through August 31, 2024,\nwhich extends several months before and after the challenged statements.\n\n At the outset, Plaintiffs demanded Defendants review and produce data from\nmore than sixteen custodians, many of whom never interacted with Zovighian and\ncould not possibly possess data relating to his scienter. As a matter of good faith,\nDefendants agreed to include ten custodians, including Zovighian and Edwards\u2019\nCFO, SVP of TAVR Sales, VP of Corporate Financial Planning, and SVP of Global\nFinance. Then, just weeks before Defendants\u2019 production deadline\u2014and after\nDefendants already agreed to review 44,000 documents\u2014Plaintiffs demanded more\nthan ten additional custodians. Defendants again agreed to add two more, and as a\nfurther effort to compromise and resolve the parties\u2019 disputes, recently agreed to add\nanother custodian, for a total of thirteen. Defendants met their production deadlines\nand have produced approximately 22,000 documents thus far.\n\n Despite numerous meet and confers over the prior months, it wasn\u2019t until\nFebruary 9, 2026, just four weeks before the Phase One production deadline, that\nPlaintiffs first demanded Defendants start their productions from January 1, 2023,\ni.e., eleven months earlier and more than a year before any of the challenged\nstatements were made. This request is neither relevant nor proportional to Phase\nOne discovery. Fed. R. Civ. P. 26(b)(1).2\n\nII. THE COURT SHOULD REJECT PLAINTIFFS\u2019 ATTEMPTS TO\n UNREASONABLY EXPAND THE SCOPE OF DISCOVERY\n\n To prevail on their claims, Plaintiffs must prove Zovighian made false\nstatements intentionally or with deliberate recklessness. Ronconi v. Larkin, 253 F.3d\n423, 432 (9th Cir. 2001) (requiring particularized facts showing defendants knew\n\n2\n In an effort to compromise, Defendants offered to produce responsive documents\nstarting in October 2023, i.e., the start of 4Q23. Plaintiffs rejected this proposal.\n 2\n\fCase 8:24-cv-02221-AH-KES Document 92 Filed 03/31/26 Page 4 of 5 Page ID\nMarch 31, 2026 #:1141\nPage 3\n\n\n\n\nstatements were false when made). And Plaintiffs must prove Zovighian had\nknowledge of falsity at the time he made his statements, i.e., that in April 2024, he\nknew TAVR sales would not grow 8-10% by the end of the year. Id.3\n\n Discovery to date has shown Plaintiffs will be unable to prove their claims.\nThe documents Zovighian received around the time he expressed confidence in\nEdwards\u2019 guidance show he believed those targets were attainable. Recognizing\nthese obstacles, Plaintiffs seek to plug the holes in their case by demanding discovery\nfrom January 2023, i.e., more than a year before Zovighian\u2019s statements. Plaintiffs\nclaim such discovery is necessary because they allege, through purported reports\nfrom former employees (\u201cFEs\u201d), that TAVR sales declined in early 2023 as hospitals\nbecame capacity-constrained. Plaintiffs\u2019 theory, however, is squarely at odds with\nthe fact that TAVR sales grew 10.3% in 2023 and continued growing in 2024.\n\n Regardless, the inquiry focuses on Zovighian\u2019s state of mind at the time he\nmade his statements. Information regarding sales or hospital capacity from up to 15\nmonths before Zovighian\u2019s statements could not possibly speak to his\ncontemporaneous knowledge. Zissa v. Cnty. of Los Angeles, 2019 WL 13074698,\nat *5 (C.D. Cal. Nov. 7, 2019) (finding request for documents related to a July 2015\nReport disproportionate to the needs of the case where class period started five\nmonths later). Even if it could, Defendants produced Zovighian\u2019s custodial data\nfrom December 1, 2023 through August 31, 2024, as well as the custodial data from\nthose involved in developing sales projections. If Zovighian considered or discussed\n2023 sales trends when expressing confidence in April 2024 that TAVR sales would\ngrow 8-10%\u2014then Plaintiffs already have that data.4\n\nIII. CONCLUSION\n\n For the foregoing reasons, the Court should deny Plaintiffs\u2019 request to extend\nthe discovery period. We look forward to addressing these issues with Your Honor\non April 1, 2026.\n\n\n\n\n3\n All of Zovighian\u2019s statements were made on April 25, 2024.\n4\n If Plaintiffs claim they need documents from January 2023 because Defendants\nsubpoenaed the FEs, Defendants are entitled to probe the veracity of the FE\nallegations and reliability of the witnesses without having to agree to an\nunreasonably extended discovery period.\n 3\n\fCase 8:24-cv-02221-AH-KES Document 92 Filed 03/31/26 Page 5 of 5 Page ID\nMarch 31, 2026 #:1142\nPage 4\n\n\n\n\n Respectfully submitted,\n\n /s/ Kristin N. Murphy\n Kristin N. Murphy\n\n\n\n\n 4\n\f","ocr_status":1,"date_upload":"2026-05-19T22:25:29.676032-07:00","document_number":"92","attachment_number":null,"pacer_doc_id":"031047377189","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Brief (non-motion non-appeal)","acms_document_guid":""}],"date_created":"2026-03-31T09:36:59.240324-07:00","date_modified":"2026-10-03T05:48:28.018961-07:00","date_filed":"2026-03-31","time_filed":"09:26:42","entry_number":92,"recap_sequence_number":"2026-03-31.002","pacer_sequence_number":305,"description":"Letter BRIEF filed by Defendants Edwards Lifesciences Corporation, Bernard J. Zovighian. regarding for Order 88 . 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