motion to compel - White Collar Fraud

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of Civil Procedure Section 2030.300, for an order compelling defendant Overstock.com, Inc.
(hereafter "Overstock" or "Defendant") to provide farther responses to the People's First Set of
Interrogatories to Overstock.
Specifically, the People will and do hereby move for an order compelling Overstock to further
respond to Special Interrogatories 8 and 14 by providing current contact information for the former
employees whose names Overstock disclosed in response to these Interrogatories.
The People met and conferred via email in good faith in an attempt to informally resolve this
dispute and have offered to enter into a protective order as a means of satisfying Overstock's asserted
privacy objections. Nonetheless, Overstock has refused to provide the People with the information
sought.
Because the People's discovery requests fall properly within the scope of permissible
discovery pursuant to the Code of Civil Procedure, Overstock should be ordered to produce the
information requested in response to the People's First Set of Interrogatories, Special Interrogatories 8
and 14.
This motion is based on this Notice of Motion and Motion, the Separate Statement in Support
of Motion, the Declaration of Matthew L. Beltramo with exhibits attached thereto, and the
Memorandum of Points and Authorities, as well as such oral argument and other evidence as may be
presented at or before the hearing on this motion.
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Dated: April 1,2011
NANCY E. O'MALLEY
Alameda County District Attorney
Matthew L. Beltramo
Deputy District Attorney
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Office of
DISTRICT ATTORNEY
Alaincdj County
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-2- Case No. RG10-546833
NOTICE OF MOTION AND MOTION TO COMPEL FURTHER INTERROGATORY RESPONSES FROM DEFENDANT
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