Respondent Response to Request for Production of Documents

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• •1234567891011121314• 151617181920212223242526RESPONSE TO REQUEST NO. 57: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 requestbecause the documentation requested either does not exist or is not in Respondent'spossession.RESPONSE TO REQUEST NO. 58: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 requestbecause the documentation requested either does not exist or is not in Respondent'spossession.RESPONSE TO REQUEST NO. 59:Respondent has made a diligent search and reasonable inquiry in an effort tolocate the requested documentation. Discovery is continuing and the Respondentreserves the right to amend this Response. Without waiving his objections to thisrequest, Respondent responds as follows: Respondent is unable to comply with thisrequest because the documentation requested does not exist.RESPONSE TO REQUEST NO. 60:Respondent objects to this request as not being reasonably calculated to lead•2728to 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 locateRESPONDENT'S RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX22
the 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 requestbecause the documentation requested does not exist.Respectfully submitted,Dated: /1/;-//ieceak&ic-•CAROLE D. BALDWIN, Attorney forRespondent, MICHAEL J. CALDWELLRESPONDENTS RESPONSE TO PETITIONER'S REQUEST FOR PRODUCTION AND INSPECTION OF DOCUMENTS - SET SIX23
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Respondent Response to Request for Production of Documents

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