motion to compel - White Collar Fraud

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RESPONSE TO SPECIAL INTERROGATORY NO. 5:
Each general objection is hereby incorporated by reference as if fully set forth herein.
Overstock objects to this interrogatory on the grounds that (1) it is overbroad, unduly burdensome,
and oppressive; (2) it seeks information neither relevant nor reasonably calculated to lead to the
discovery of admissible evidence; (3) it seeks information protected by California's constitutional
right of privacy; (4) it is vague and ambiguous as to the terms and/or phrases "regarding any
employment, consulting, or contracting relationship;" and (5) it is vague and ambiguous as to the
terms and/or phrases "EMPLOYEES [who] SET COMPARISON PRICES," as Overstock does
9 I not itself designate certain employees, consultants, or contractors as those that set comparison
10 prices. Nothing in Overstock's response is intended as or shall be interpreted as a waiver of any
11 applicable privilege or protection of information from disclosure.
12 Subject to and without waiving the foregoing objections, Overstock responds as follows:
13 EMPLOYEES do not SET COMPARISON PRICES. EMPLOYEES typically receive and review,
14 and on occasion may modify COMPARISON PRICES submitted to Overstock by its vendors and
15 suppliers. Notwithstanding the foregoing, the number of EMPLOYEES who typically received
16 and reviewed, and on occasion may have modified COMPARISON PRICES is approximately:
17 2006-130
18 2007-130
19 2008-180
20 2009-120
21 2010-173
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SPECIAL INTERROGATORY NO. 6:
IDENTIFY each CURRENT EMPLOYEE who SET COMPARISON PRICES at any time
on or after January 1, 2006.
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55.51782/3971861.
Case No. RG10-546833
RESPONSES TO FIRST SET OF INTERROGATORIES