motion to compel - White Collar Fraud

asserting an obligation to do so, and without waiving the objections asserted herein, Overstock
reserves the right to amend and/or supplement its responses at the appropriate time.
8. Overstock objects that Plaintiffs definitions of "YOU," "YOU OR ANYONE ON
YOUR BEHALF," and "OVERSTOCK" are overbroad and impose upon Overstock duties beyond
those required under the scope of discovery as defined in the California Code of Civil Procedure at
least because the definition encompasses persons and entities not within the control of Overstock.
9. Overstock objects that Plaintiffs definition of "DOCUMENT" is overbroad to the
extent it purports to impose upon Overstock duties beyond those required under the scope of
discovery as defined in the California Code of Civil Procedure,
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12. Overstock's response is made expressly subject to, and without in any way waiving
or intending to waive, any questions or objections as to the competency, relevancy, materiality,
privilege or admissibility as evidence or for any other purpose, of any of the documents referred to
or produced, or of the responses given herein, in any proceeding (including the trial of this action
or in any subsequent proceeding). These responses are made subject to Overstock's right to object
to any discovery proceeding involving or relating to the subject matter of the requests responded
to herein.
13. Overstock's objections to the disclosure of any information requested by the
Interrogatories are not and shall not be construed as an admission by Overstock that any such
information exists.
RESPONSES
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FORM INTERROGATORY NO. 1.1:
State the name, ADDRESS, telephone number, and relationship to you of each PERSON
who prepared or assisted in the preparation of the responses to these interrogatories. (Do not
identify anyone who simply typed or reproduced responses.)
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155.51782/3971861,
Case No. RG10-546833
RESPONSES TO FIRST SET OF INTERROGATORIES