motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
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ight 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 "EMPLOYEE [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 PR'lCES. 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 />
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suppliers. Notwithstanding the foregoing, CURRENT EMPLOYEES who typically received and<br />
reviewed, and on occasion may have modified COMPARISON PRICES after January 1, 2006 by<br />
DEPARTMENT and/or PRODUCT/LINE are identified in the document produced herewith and<br />
identified as OSTK3 - OSTK4. ,<br />
SPECIAL INTERROGATORY NO. 8:<br />
IDENTIFY each FORMER EMPLOYEE who SET COMPARISON PRICES at any time<br />
on or after January 1, 2006.<br />
RESPONSE TO SPECIAL INTERROGATORY NO. 8:<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 "FORMER EMPLOYEE who SET COMPARISON PRICES," as Overs<strong>to</strong>ck<br />
does not itself designate certain employees, consultants, or contrac<strong>to</strong>rs as those that set<br />
!55.51782/3971861.<br />
Case No. RG10-546833<br />
RESPONSES TO FIRST SET OF INTERROGATORIES
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