motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
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n. Overs<strong>to</strong>ck was issued a business license by the city of Tooele, Utah on Oc<strong>to</strong>ber 21,<br />
2010, License Number 2010235, which expires on or about December 31, 2011.<br />
o. Overs<strong>to</strong>ck was issued a business license by the city of Provo, Utah on January 10,<br />
2011, License Number 52500, which expires December 31, 2011.<br />
SPECIAL INTERROGATORY NO. 1:<br />
Identify the job title(s) which YOU currently use lo identify EMPLOYEES who SET<br />
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COMPARISON PRICES. " . •<br />
RESPONSE TO SPECIAL INTERROGATORY NO. 1:<br />
Each general objection is hereby incorporated by reference as if fully set forth herein.<br />
Overs<strong>to</strong>ck objects <strong>to</strong> this interroga<strong>to</strong>ry on the grounds that (1) it is overbroad, unduly burdensome,<br />
and oppressive; (2) it seeks information neither relevant nor reasonably calculated <strong>to</strong> lead <strong>to</strong> the<br />
discovery of admissible evidence; (3) it seeks information protected by California's constitutional<br />
right of privacy; (4) it is vague and ambiguous as <strong>to</strong> the terms and/or phrases "regarding any<br />
employment, consulting, or contracting relationship;" and (5) it is vague and ambiguous as <strong>to</strong> the<br />
terms and/or phrases "EMPLOYEES who SET COMPARISON PRICES," as Overs<strong>to</strong>ck does not<br />
itself designate certain employees, consultants, or contrac<strong>to</strong>rs as those that set comparison prices.<br />
Nothing in Overs<strong>to</strong>ck's response is intended as or shall be interpreted as a waiver of any<br />
applicable privilege or protection of information from disclosure.<br />
Subject <strong>to</strong> and without waiving the foregoing objections, Overs<strong>to</strong>ck responds as follows:<br />
EMPLOYEES do not SET COMPARISON PRICES. EMPLOYEES typically receive and review,<br />
and on occasion may modify COMPARISON PRICES submitted <strong>to</strong> Overs<strong>to</strong>ck by its vendors and<br />
suppliers. The job title(s) of current EMPLOYEES who typically receive and review, and on<br />
occasion may modify COMPARISON PRICES are:<br />
a. Merchandise Operations Manager<br />
b. Merchandise Operations Specialist<br />
c. Merchandise Operations Coordina<strong>to</strong>r<br />
55.51782/3971861.<br />
-7- CaseNo. RGIO-546833<br />
RESPONSES TO FIRST SET OF INTERROGATORIES
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