Respondent Response to Request for Production of Documents

• •1234567891011121314• 1516171819202122232425262728evidence. Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: See responses to request numbers 30 and 31 above.RESPONSE TO REQUEST NO. 52:Respondent objects to this request as it requires Respondent to producedocuments already produced in past responses to Petitioner's Requests forProduction and Inspection of Documents and is therefore burdensome andoppressive. Petitioner is referred to responses served on August 22, 011, June 27,2011, May 7, 2010, July 15, 2009 and August 18, 2008. Respondent has made adiligent search and reasonable inquiry in an effort to locate the requesteddocumentation. Discovery is continuing and the Respondent reserves the right toamend this Response. Without waiving his objections to this request, Respondentresponds as follows: The documents requested have been lost or misplaced and areno longer available to Respondent. Petitioner is referred to Respondent's previousresponses for documents in Respondent's possession at the time of the responses.RESPONSE TO REQUEST NO. 53:Respondent objects to this request as not being reasonably calculated to leadto the discovery of admissible evidence and as such is burdensome and oppressive.Respondent has made a diligent search and reasonable inquiry in an effort to locatethe requested documentation. Discovery is continuing and the Respondent reservesthe right to amend this Response. Without waiving his objections to this request,Respondent responds as follows: Respondent is unable to comply with this requestRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX20