motion to compel - White Collar Fraud

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8. On March 25, 2011,1 received an email from counsel for Overstock, asserting that one of the
principal legal authorities cited in my March 22, 2011, email was distinguishable from this case
and requesting that the parties table this issue - with an open extension on a motion to compel -
so as to allow other discovery to go forward. A true and correct copy of this email is attached
hereto as Exhibit 6.
. 9. Later in the day on March 25, 2011,1 responded via email, indicating that the People could not
agree to table this issue inasmuch as obtaining contact information of potential witnesses was an
important and necessary preliminary step in the discovery process. The email went on to state
that, although the People would welcome any legal authorities that Overstock was willing to
provide, the parties appeared to have reached an impasse. The email reiterated the People's
willingness to enter into a protective order to address Overstock's privacy concerns. A true and
\t copy of thi
10. As of the date of this declaration, I have not heard anything further on this discovery issue from
Overstock's counsel.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
Executed this 1st day of April, 2011, in Oakland,
Matthew L. Beltramo
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Office of
DISTRICT
AlBmcda County
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-3- Case No. RG10-546833
BELTRAMO DECLARATION IN SUPPORT OP MOTION TO COMPEL FURTHER INTERROGATORY RESPONSES