motion to compel - White Collar Fraud

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Office of
DISTRICT A
Alimedi Coiuuy
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NANCY E. O'MALLEY
District Attorney of Alameda County
Matthew L. Beltramo, Deputy District Attorney
(State Bar No. 184796)
7677 Oakport Street, Suite 650
Oakland, CA 94621
Telephone: (510) 569-9281
Facsimile: (510) 569-0505
Attorneys for Plaintiff (Additional counsel listed
on Appendix A to Notice of Motion/Motion to Compel)
THE PEOPLE OF THE STATE OF
CALIFORNIA,
Plaintiff
vs.
OVERSTOCK.COM, INC., et al.,
Defendants
SUPERIOR COURT OF CALIFORNIA
'8829874*
AuwSBf e^ufffY
IN AND FOR THE COUNTY OF ALAMEDA
No. RG10-546833
MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF
PLAINTIFF'S MOTION TO COMPEL
FURTHER RESPONSES TO FIRST SET
OF INTERROGATORIES TO
DEFENDANT OVERSTOCK.COM, INC.
*
Date and Time: May 5, 2011, 2:00 p.m.
Dept: 20
Reservation: #116751
Assigned for-All Purposes to the
Honorable Robert B. Freedman
Complaint Filed:
Am. Answer Filed:
November 17,2010
March 7, 2011
Plaintiff, the People of the State of California (the "People,") respectfully submit this
Memorandum Of Points And Authorities in support of the Motion To Compel Further Responses To
First Set Of Interrogatories to Defendant Overstock.com, Inc. (hereinafter "Defendant" or
"Overstock") pursuant to Code of Civil Procedure Section 2030.300.
I. INTRODUCTION
By this motion, the People seek to compel defendant Overstock to further respond to two of the
*
People's First Set of Interrogatories, Special Interrogatories 8 and 14, by providing current contact
information for former employees—now potential witnesses—whose names and other information
Overstock has already disclosed in response to these Interrogatories. Overstock has refused to provide
-1- Case No. RG10-546833
MPA IN SUPPORT OF MOTION TO COMPEL FURTHER INTERROGATORY RESPONSES