motion to compel - White Collar Fraud

suppliers. Notwithstanding the foregoing, FORMER EMPLOYEES who typically received and
reviewed, and on occasion may have modified COMPARISON PRICES after January 1,2006 by
DEPARTMENT and/or PRODUCT/LINE are identified in the document produced herewith and
identified as OSTK5 - OSTK6.
SPECIAL INTERROGATORY NO. 10:
How many EMPLOYEES currently work as OVERSTOCK BUYERS?
9
10
11
12
13
14
15
16
17
18
19
20
21
RESPONSE TO SPECIAL INTERROGATORY NO. 10:
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;'1 and (5) it is vague and ambiguous as to the
terms and/or phrases "OVERSTOCK BUYERS." Nothing in Overstock's response is intended as
or shall be interpreted as a waiver of any applicable privilege or protection of information from
disclosure.
Subject to.and without waiving the foregoing objections, Overstock responds that the
approximate number of EMPLOYEES that currently work as OVERSTOCK BUYERS is as
follows: 81.
22
23
24
25
SPECIAL INTERROGATORY NO. 11:
inclusive?
How many EMPLOYEES worked as OVERSTOCK BUYERS between 2006 and 2010,
26
27
28
JS5.-5178M97I861.
-15- CaseNo. RG10-546833
RESPONSES TO FIRST SET OF INTERROGATORIES