motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
motion to compel - White Collar Fraud
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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 "OVERSTOCK BUYER." Nothing in Overs<strong>to</strong>ck's response is intended as<br />
or shall be interpreted as a waiver of any applicable privilege or protection of information from<br />
disclosure.<br />
Subject <strong>to</strong> and without waiving the foregoing objections, Overs<strong>to</strong>ck refers <strong>to</strong> and<br />
incorporates the document produced herewith and identified as OSTK7.<br />
9<br />
10<br />
11<br />
12<br />
SPECIAL INTERROGATORY NO. 13:<br />
For each OVERSTOCK BUYER identified in response <strong>to</strong> Interroga<strong>to</strong>ry #12 [sic], identify<br />
each DEPARTMENT and/or PRODUCT LINE for which that EMPLOYEE regularly acted as an<br />
OVERSTOCK BUYER on or after January 1, 2006.<br />
c H 15<br />
RESPONSE TO SPECIAL INTERROGATORY NO. 13:<br />
Each general objection is hereby incorporated by reference as if fully set forth herein.<br />
13<br />
16<br />
17<br />
18<br />
19<br />
20<br />
21<br />
22<br />
23<br />
24<br />
25<br />
26<br />
,' - . 27<br />
28<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;" (5) it is vague and ambiguous as <strong>to</strong> the<br />
terms and/or phrases "OVERSTOCK BUYER," as Overs<strong>to</strong>ck does not itself designate certain<br />
employees, consultants, or contrac<strong>to</strong>rs as "OVERSTOCK BUYER;" and (6) it is vague and<br />
ambiguous as <strong>to</strong> the meaning of the word "regularly." Nothing in Overs<strong>to</strong>ck's response is<br />
intended as or shall be interpreted as a waiver of any applicable privilege or protection of<br />
information from disclosure.<br />
Subject <strong>to</strong> and without waiving the foregoing objections, Overs<strong>to</strong>ck refers <strong>to</strong> and .<br />
incorporates the document produced herewith and identified as OSTK7.<br />
155.51782/3971861.1<br />
-17- Case No. RG10-546833<br />
RESPONSES TO FIRST SET OF INTERROGATORIES
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