THANKS SILVERSURFER, I like this part from doc 148

digEcor’s intense focus on these trivial complaints appears intended to obscure the most fundamental issue—that e.Digital has produced tens of thousands of pages of documents, has made good faith assurances that its production is complete, and has forthrightly attempted to communicate its discovery status at all times. It can do nothing more. When given their proper weight, these facts should be fully dispositive of digEcor’s motion. digEcor’s proposed remedy of a date certain for production is nonsensical and truly moot.

For the reasons stated above and in e.Digital’s opposition memorandum, digEcor’s Motion to Compel should be denied in its entirety.