Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 88

MOTION to Compel Production of Documents from Heartland and Baker & Daniels by Counter Claimant Forest River Inc. (Attachments: # 1 Exhibit A - Excerpt of '747 Patent, # 2 Exhibit B - Email of 3/14/05, # 3 Exhibit C - Excerpt of '841 Patent, # 4 Exhibit D - Excerpt of '650 Patent, # 5 Exhibit E - Excerpt of Taylor Dep., # 6 Exhibit F - FR Doc. Req. #9, # 7 Exhibit G - FR Doc. Req. #32, # 8 Exhibit H - Heartland Resp. to #9, # 9 Exhibit I - Heartland Resp. to #32, # 10 Exhibit J - B&D Subpoena, # 11 Exhibit K - Gallagher diary, # 12 Exhibit L - Brotherson CC, # 13 Exhibit M - Brotherson Letter, # 14 Appendix Rule 37 Certification, # 15 Supplement Supplement to Certification)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 88 Att. 8

case 3:08-cv-00490-TLS document 88-9

filed 02/01/10 page 1 of 1

billing stateme ts therefore, where that correspondence occurred prior to the issue date of the patent in suit RESPONSE: passed. Heartl burdensome.
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refers to communications prior to the issue date of the patent in suit. Heartland objects to this request as untimely. The deadline for discovery has d further objects to this request as overly broad, vague, ambiguous, and unduly eartland objects to this request to the extent that it is not reasonably calculated to

lead to the disc very of admissible, relevant evidence. Heartland also objects to this request to the extent it se ks information or documents that are unreasonably duplicative or cumulative of documents alre dy provided to Forest River. Heartland further objects to the extent that this request seeks d cuments that are subject to the attorney-client privilege and outside the scope of any waiver oft at privilege by Heartland. Heartland further objects to this request to the extent that it seeks do uments subject to the attorney work product doctrine or any other applicable privilege.

RE

VEST N .33: All documents and things provided to and received from any person who

Heartland has r quested be an expert witness in the present litigation. RESPONSE: eartland objects to this request as untimely. The deadline for discovery has d further objects to this request as overly broad and unduly burdensome. Heartland objec s to this request to the extent that it is not reasonably calculated to lead to the discovery of ad issible, relevant evidence. Heartland also objects to this request to the extent it seeks informati n or documents that are unreasonably duplicative or cumulative of documents already provide to Forest River, including all documents and information relied upon by

Heartland's exp rt witness, Jay Taylor, in creating his expert report in this matter. Heartland

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