Paramount Pictures Corporation v. ReplayTV, Inc., Joint Stipulation ...

12345678910111213141516171819202122232425262728documents. Defendants object to the extent plaintiffs seek documents protected byattorney-client privilege, work product doctrine or any other applicable privilege.DOCUMENT REQUEST NO. 27Any and all Documents relating to, regarding, referring to, or reflecting anyCommunications between You and any investor or potential investor in You ordefendant SONICblue Inc., including but not limited to any individual investor, anypartnership, and any institutional investor such as an investment banking firm, retailbrokerage firm, venture capital firm, or mutual fund.RESPONSE TO DOCUMENT REQUEST NO. 27Defendants object on the ground that demand for “ [a]ny and all Documentsrelating to, regarding, referring to, or reflecting any Communications between Youand any investor or potential investor in You” is overly broad, burdensome andharassing. Defendants object that Plaintiffs seek documents that are not relevant ornecessary to determination of any of the issues underlying Plaintiffs’ suit forinjunctive and declaratory relief. Therefore, Plaintiffs’ request is not reasonablycalculated to lead to the discovery of admissible evidence. Defendants object to theextent Plaintiffs seek confidential documents. Defendants object to the extentPlaintiffs seek documents protected by attorney-client privilege, work productdoctrine or any other applicable privilege.DOCUMENT REQUEST NO. 28Any and all Documents relating to, regarding, referring to, or reflecting anyCommunications between You and any investment analyst, research analyst,securities dealer, or securities broker, regarding You or any of Your products orservices.70