Eight Mile Style, LLC et al v. Apple Computer, Incorporated
Filing
107
MOTION to Strike 79 Statement, 74 Response to Motion,,,,,,,,,,,,, Declaration of Patrick Sullivan and Statement of Material Facts and Conditional Motion to Strike Plaintiffs' Late-Produced Documents by Aftermath Records, Apple Computer, Incorporated. (Attachments: # 1 Index of Exhibits TO DEFENDANTS AFTERMATH RECORDS AND APPLE INC.S MOTION TO STRIKE DECLARATION OF PATRICK SULLIVAN AND PLAINTIFFS STATEMENT OF MATERIAL FACTS AND CONDITIONAL MOTION TO STRIKE PLAINTIFFS LATE-PRODUCED DOCUMENTS, # 2 Exhibit Declaration of Melinda LeMoine In Support of Defendants Aftermath Records and Apple Inc.s Motion to Strike Declaration of Patrick Sullivan and Plaintiffs Statement of Material Facts and Conditional Motion to Strike Plaintiffs Late-Produced Documents, # 3 Exhibit 1-A: Excerpts of transcript pages from the depositions of Patrick Sullivan taken on September 18, 2008 and October 1, 2008, # 4 Exhibit 1-B: E-mail between Ramona DeSalvo and Patrick Sullivan, dated August 27, 2008, # 5 Exhibit 1-C: E-mail between Ramona DeSalvo and Patrick Sullivan, dated August 20, 2008, # 6 Exhibit 1-D: Plaintiff Eight Mile Style, LLCs Responses to Defendants First Set of Interrogatories, dated March 21, 2008, # 7 Exhibit 1-E: Plaintiff Martin Affiliated, LLCs Responses to Defendants First Set of Interrogatories, dated March 21, 2008, # 8 Exhibit 1-F: Plaintiff Eight Mile Style, LLCs Responses to the Defendants First Set of Requests for Production of Documents, dated March 21, 2008, # 9 Exhibit 1-G: Plaintiff Martin Affiliated, LLCs Responses to Defendants First Requests for Production of Documents, dated March 21, 2008, # 10 Exhibit 1-H: Plaintiff Eight Mile Style, LLCs Responses to the Defendants Second Set of Requests for Production of Documents, dated August 8, 2008, # 11 Index of Exhibits 1-I: Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Requests for Production of Documents, dated August 8, 2008, # 12 Exhibit 1-J: Plaintiff Eight Mile Style, LLCs Responses to Defendants Second Set of Interrogatories, dated August 8, 2008, # 13 Exhibit 1-K: Plaintiff Martin Affiliated, LLCs Responses to Defendants Second Set of Interrogatories, dated August 8, 2008, # 14 Exhibit 2: Anderson v. United States, 39 Fed. Appx. 132, 2002 WL 857742 (6th Cir. May 3, 2002)) (Klaus, Kelly)
<![CDATA[
Eight Mile Style, LLC et al. v. Apple Computer Inc., et al. Case No. 2:07-CV-13164
EXHIBIT 1-F Plaintiff Eight Mile Style, LLC's Responses to the Defendants' First Set of Requests for Production of Documents, dated March 21, 2008
5005843.1
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
EIGHT MILE STYLE LLC
and
MART1N AFFILIATED
Plaintiffs
LLC
Case
No
207-cv-13164 Diggs Taylor Judge Donald
Scheer
vs
Hon Anna
Magistrate
APPLE
COMPUTER INC
and
AFTERMATH AFTERMATH
RECORDS db/a ENTERTAINMENT
Defendants
Howard
Hertz
Hertz
Schram
P26653 PC Road 300
48302
Richard
Busch Ballow
Street Street
TN BPR14594
Plaza
King
1760 South Telegraph Bloomfield
Hills
1100 Union 315 Union
Nashville
MI
248
335-5000
TN
37201
hhertz@hertzschram.com
615
259-3456
rbuschkingballow.com
Attorney
for Plaintiffs
PLAINTIFF EIGHT MILE STYLE
LLCS RESPONSES TO THE
OF DOCUMENTS
objections
DEFENDANTS FIRST SET OF REQUESTS
Plaintiff
FOR PRODUCTION
provides the
Eight
Mile
Style
LLC Eight Mile
for
following
and
responses
to
the First
Set of Requests
Production
of Documents
Requests
propounded
by
Defendants Apple
Inc
named
as
Apple
Computer Inc and Aftermath Records
cl/b/a
Aftermath
Entertainment
GENERAL OBJECTIONS
The
following General Objections apply
to
and
are
incorporated
in
each
and
every
response
to
each
and
every
Request
whether
or
not
such
General
Objections
are
expressly
incorporated
by reference
in
such
response
Eight
Mile objects
to
the
Requests
to
the
extent
they
collectively
or individually
seek
information
or
documents
subject
to
or
protected
by
the
attorney-client
privilege
the
attorney
work
product
privilege
or any
other privilege or protection
from disclosure
Eight
Mile
hereby
invokes
all
such
privileges
to
the
extent
implicated
by
each
Request
and
exclude
privileged
and protected
information
from
its
responses
to
the
Requests
Any
disclosure
of
information
protected
by
those
privileges
is
inadvertent
and
is
not
intended
to
waive
any
privilege
or protection
Eight
Mile
objects
to
the
Requests
to
the
extent
they
purport
to
impose
on
Plaintiff
any obligations
that
are
different
from or
greater
than
any duty
imposed
by the Federal
Rules
of
Civil
Procedure
the
Local
Rules
of the
United
States
District
Court
for
the
Eastern
District
of Michigan
or
any other applicable law or rule
Eight
Mile
objects
to
the
Requests
as
duplicative
unduly
burdensome
and
harassing
to
the
extent
they
seek
information
that
is
equally
available
to
Defendants
or
information
that
could
be derived
or ascertained
by Defendants
with
substantially
the same
effort
that
would be
required of Plaintiffs
from review
of the documents
produced
in this
case
Eight
Mile objects
to
the Requests
to
the extent
they
seek
disclosure
of items that
are not in Eight
Miles possession custody
Mile
or control
or that
are
publicly
available
Eight
objects
to
the
Requests
to
the
extent
they
seek
items
that
are
confidential
proprietary
trade secret
information
andlor
competitively
sensitive
material
Eight
Mile
will
disclose
such
responsive
non-privileged
information
only
upon
entry
of
and
in
accordance
with
the terms
of an appropriate
protective
order
To
the
extent
that
the
Requests
seek
information
concerning
an
identified
contention
or factual
issue
Eight
Mile
objects
on the grounds
that
Eight
Mile has not completed
its
investigation
of the
facts
relevant
to
this
case
Eight
Miles
responses
are
necessarily
preliminary
and
are
made
without
prejudice
to
its
right
to
disclose
introduce
or
rely
upon
information
or documents
that
may
be
later discovered
or produced
Eight
Mile
will
make
reasonable
efforts
to
search
for
information
in
the
places
where
it
is
reasonably
likely
to
be found
and Eight
Mile objects
to
the
Requests
to
the
extent
they
purport
to
require
broader
search
In
responding
to
the Requests
Eight
Mile does
not
waive
or
intend
to
waive
any
privilege or objection
including
but not
limited to any objections
to
the competency
relevance
materiality
or
admissibility
of
any
of
the
items
disclosed
in
response
to
the
Requests
No
objection
or
response
made
in
these
responses
and objections
shall
be deemed
to
constitute
representation
by Eight Mile
as to
the existence
or non-existence
of the items requested
Eight
Mile
objects
to
Requests
containing
the
defined
term
documents
the term
as
as
vague
ambiguous
overly
broad
and
unduly
burdensome
to
the
extent
that
used
in
any
Request
expands
Eight
Miles
duty
to
produce
documents
or
items
beyond
the
scope
required
of the
Federal
Rules
of Civil
Procedure
Eight
Mile
also
objects
to
Requests
containing
the defined
term
documents
is
to
the extent
that
any Request
containing
the defined
term seeks
information
that
privileged
protected
and confidential
Eight
Mile
also
objects
to
the
extent
use
of the
defined
term
documents
is
intended
to
seek
information
or
items
that
are
not
reasonably
calculated
to
lead to
the discovery
of admissible
evidence
of information
10
Eight
Mile objects
to
the Requests
as
vague
Mile
to
ambiguous
overly
broad
and unduly
burdensome
to
the extent
any Request
requires Eight
provide
information
that
is
different
from or
at
different
time than
as
required
under Federal
Rule of
Civil
Procedure
26a2
broad and unduly
11
Eight
Mile objects
to
the Requests
as
vague ambiguous
overly
burdensome
to
the extent
any Request
commands
or requires Eight
Mile
to
provide
responses
or
items
in
any manner
or to
any extent
that
is
different
that
the
scope
provided
by Rules
33
and 34
of
the
Federal
Rules
of
Civil
Procedure
12
Eight
Mile objects
to
Requests
containing
the
defined
term
Eminem as
vague
ambiguous
overly
broad and unduly
burdensome
to
the extent
the term includes
any persons
or
entity
or entities
other
than
the
individual
Marshall
Mathers
III
professionally
known
as
Eminem
13
Mile
the
definition
Eight
objects
to
contained
in
paragraph
10
of
Defendants
Definitions
and
Instructions
as
vague
ambiguous
overly
broad
unintelligible
and
unduly
burdensome
Eight
Mile
interprets
defined
terms
as
set
forth
herein
and other terms
according
to
its
best
understanding
of such
terms including
the Federal
Rules
of Civil
Procedure
OBJECTIONS REQUEST
All
AND RESPONSES TO REQUESTS
NO.1
documents
that
You reviewed
or
relied
upon
in
drafting
Your
Complaint
in
this
action
ANSWER TO REQUEST
Eight
NO.1
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
and unduly
burdensome
Eight
Mile
further
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or control of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they have
not been already
produced
REQUEST
NO.2
that
All documents
You
refer
to
in
Your Complaint
ANSWER TO REQUEST
Eight
NO.2
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the
possession
custody
or control
of Defendants
Subject
to
and without
waiver
of
the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not been already
produced
REQUEST
All
NO.3
documents
that
You
refer
to
in
any
of Your
responses
to
Defendants
First
Set of
Interrogatories
served
concurrently
with
these Requests
for
Production
ANSWER TO REQUEST
Eight
NO.3
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
to
the
extent
the information
requested
is
within
the possession
custody
or
control
of Defendants
Subject
to
and without
waiver
of the foregoing
General
and Specific
Objections
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not been already
produced
REQUEST
All
NO.4
documents
that
You
reviewed
or
relied
upon
in
preparing
Your
responses
to
Defendants
First
Set of Interrogatories
ANSWER TO REQUEST
Eight
NO.4
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
and unduly
burdensome
Eight
Miles
further
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or
control
of Defendants
Subject
to
and
without
waiver
of
the
foregoing
General
and
Specific
Objections
Plaintiffs
will
produce relevant
non-privileged
documents
responsive
to
this request
to
the extent
they
have not been already
produced
REQUEST
NO.5
that
All documents
You
refer
to
in
Your
Initial
Disclosures
in this
action
ANSWER TO REQUEST
Eight
NO.5
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
the information
requested
is
within
the possession
custody
or
control
of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they have
not
been already
produced
REQUEST
NO.6
that relate to
All documents
any of Your
allegations
in
Your Complaint
ANSWER TO REQUEST
Eight
NO.6
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague ambiguous
relate
overly
broad and unduly burdensome
in that
it
does
not define
what
it
means
to
to
any of Eight
Miles
allegations
in
the
Complaint
Eight
Mile
further
objects
to
this
Request
to
the extent
the
information
requested
is
within
the possession
custody
or control
of Defendants
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not been already
produced
REQUEST
All
NO.7
documents
that
support
or
that
are
contrary
to
Your
contention
that
Apple
has
distributed
Eminem
recordings
embodying
the
works
that
are
the
subject
of
your
Complaint
pursuant
to
purported
license
with
Universal
as
alleged
by You
in
Paragraph
12
of Your
Complaint
ANSWER TO REQUEST
Eight
NO.7
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad and unduly
burdensome
Eight
Mile objects
to
the
language
contrary
to
as
vague
and
ambiguous
and
would
involve
analysis
by
counsel
which
is
protected
by the
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or control
of Defendants
Subject
to
and
without
waiver
of the foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they have
not been already
produced
REQUEST
NO.8
that
All documents
support
or that
are
contrary to
Your contention
that
Eight
Mile and
Martin have
never
authorized
Universal
to
license
the
works
to
Apple
as
alleged
by You
in
Paragraph
12
of Your Complaint
ANSWER TO REQUEST
Eight
NO.8
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by
the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad and unduly
burdensome
Eight
Mile objects
to
the
language
contrary
to
the
as
vague
and
ambiguous
and
would
involve
analysis
by
counsel
which
is
protected
by
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or control
of Defendants
Eight
Mile
further
objects
to
the extent
the request
seeks
expert
testimony
or opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not been already
produced
REQUEST
NO.9
that
All documents
support or
that
are
contrary
to Your contention
that
Eight
Mile and
Martin
have never
authorized
Universal
to
engage
in
reproduction
or
distribution
of the
digital
transmissions
through
third
parties
or otherwise
as
alleged
by You
in
Paragraph
12
of Your
Complaint
ANSWER TO REQUEST
See Response
to
NO.9
Request
No
REQUEST
NO 10
that
All documents
support
or that
are
contrary
to Your
contention
that
Universal
has
on any number
of occasions
asked
Eight
Mile and Martin
to
execute
agieements
allowing
Apple
to
reproduce
and
distribute
the
digital
transmissions
but
Eight
Mile
and
Martin
have
not
provided
that
permission
as alleged
by You
in Paragraph
12
of Your
Complaint
ANSWER TO REQUEST
See Response
to
NO
10
Request
No
REQUEST
NO 11
that
All documents
support
or that
are
contrary
to Your
claim
that
You have
suffered
damages
including
without
limitation
any
actual
damages
that
you
may
seek
under
17
U.S.C
504
as
result
of any of Defendants
actions
ANSWER TO REQUEST
See Response
to
NO 11
No
Request
REQUEST
NO 12
that
All documents
constitute
refer
to
or
relate
to
communications
You have had
with
any Person
including
without
limitation
Eminem
or
any of
Eminems
et
representatives
regarding
this
lawsuit
or the
lawsuit
captioned
Productions
LLC
at
Aftermath
Records
d/b/a
Aftermath
Entertainment
et
at
Case
No
CV-07-03314
C.D Cal
or
any of the matters
alleged
in either
action
ANSWER TO REQUEST
Eight
NO
12
General
Mile incorporates
its
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by
the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
unduly
burdensome
and not reasonably
calculated
to
lead to
the
discovery
of admissible
evidence
Eight
Mile
further
objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or
control
of Defendants
Eight
Mile
further
objects
to
the extent
that
such
documents
are not
relevant
to
the
claims
in
the
above-captioned
matter
Eight
Mile
further
objects
to
this
Interrogatory
to
the
extent
it
seeks
discovery
in
separate
action
entitled
F.B.T
Productions
LLCJ
et
at
Aftermath
Records
d/b/a
Aftermath
Entertainment
et
al
Case
No
CV-07-033 14
C.D Cal
scheduling
to
which
Eight
Mile
is
not
party
and which
such
discovery
is
subject
to
separate
order inapplicable
to
this
action
Eight
Mile
further
objects
to
the extent
the request
seeks
expert
testimony
or
opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not been already
produced
REQUEST
NO
13
communications
All documents
that
constitute
refer
to
or relate
to
You have had
with
any Person
regarding
Eminem
ANSWER TO REQUEST
Eight
NO
13
General
Mile incorporates
its
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by
the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
10
broad
unduly
burdensome
and not reasonably
calculated
to
lead to
the
discovery
of admissible
evidence
in
that
it
does not
define
or limit
communications
with
any Person
the
or
regarding
Eminem
within
the
Eight
Mile
further
objects
to
this
Request
to
the
extent
information
requested
is
possession
custody
or control
of Defendants
Eight
Mile
further
objects
to
the
extent
the request
seeks
expert
testimony
or opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not already
been produced
REQUEST
NO
14
communications
All documents
that
constitute
refer
to
or
relate
to
You have had
with
Eminem
or any of
Eminems
representatives
ANSWER TO REQUEST
See
NO 14
13
Response
to
Request
REQUEST
NO
15
that
All documents
discuss
refer
to
or
relate
to
the
March
1998 Agreement
including
without
limitation
Paragraph
thereof
ANSWER TO REQUEST
Eight
NO 15
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
unduly
burdensome
and not
reasonably
calculated
to
lead to
the
discovery
of admissible
evidence
Eight
Mile further objects
to
this
Request
to
the
extent
the
information
requested
is
within
the possession
custody
or control
of Defendants
Eight
Mile
further
objects
to
the extent
11
the request
seeks
expert
testimony
or opinion
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the
extent
they
have not already
been produced
REQUEST
NO 16
that
All documents
discuss
refer
to
or relate
to
the
July
2003
Agreement
including
without
limitation
Paragraph
thereof
ANSWER TO REQUEST
See
NO
16
15
Response
to
Request
REQUEST
All
NO
17
that
documents
discuss
refer
to
or
relate
to
the
distribution
of
Eminem
sound
recordings
that
embody
any
of the
works
that
are
the
subject
of your
Complaint
including
the
distribution
of the same
as
digital
downloads
mastertones
ringtones
or digital
streams
ANSWER TO REQUEST
See Response
to
NO 17
15
Request
REQUEST
NO 18
sufficient to
All documents
identi
all
Persons
that
have an ownership
interest
in
each
of
the works for which
You
seek
damages
through
Your Complaint
ANSWER TO REQUEST
Eight
NO
its
18
General
Mile incorporates
Objections
above
Subject
to
and without
waiver
of the foregoing
General
Objections
Eight
Mile responds
that
relevant
information
that
may be
within
the
scope
of this
Request
may
be
determined
by
Defendants
examination
of the
Complaint
filed
in
this
matter
in
particular
paragraph
and
12
collective
Exhibit
attached
to
the
Complaint
Defendants
are
in possession
of the
Complaint
and Exhibit
referenced
therein
and the burden of deriving
that
information
is
substantially
the
same
for
Defendants
as
for
Eight
Mile
and therefore
Eight
Mile
refers
Defendants
to
same
Further
see
Schedule
Plaintiffs
Compositions
attached
to
Eight
Miles
htenogatory
Responses
Notwithstanding
the
foregoing
Eight
Mile
will
produce
relevant
non-privileged
documents
responsive
to
this
request
to
the extent
they have
not
already
been produced
REQUEST
NO 19
sufficient to identify
All documents
any
predecessors
successors
parents
subsidiaries
divisions
affiliates
or other entities
within
the operation
or
control of Plaintiff
ANSWER TO REQUEST
Eight
NO
19
General
Mile incorporates
its
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by
the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
unduly
burdensome
and not
reasonably
calculated
to
lead to
the
discovery
of admissible
evidence
Eight
Mile
will
produce relevant
non-privileged
documents
responsive
to
this
request
to
the extent
they
have not been already
produced
REQUEST
NO 20
that
All documents
discuss
relate
to
or refer
to
any
expert
witnesses
that
You have
communicated
with
regarding
the
claims
in
this
action
including
without
limitation
all
correspondence
billing
records
documents
received
from such
expert
witness documents
relied
upon by such
expert
witness
in
forming
his
or her opinion
and
curriculum
vitae
for
such
expert
witness
retained by
You
13
ANSWER TO REQUEST
Eight
NO 20
its
Mile incorporates
General
Objections
above
Eight
Mile
specifically
objects
to
this
Request
to
the
extent
it
calls
for
information
protected
by the
attorney-client
privilege
and
work
product
doctrine
Eight
Mile
further
objects
to
this
Request
as
vague
ambiguous
overly
broad
unduly burdensome
and not
reasonably
calculated
to
lead to
the
discovery
of admissible
evidence
The
expert
witness
disclosure
deadline
has
not
yet occurred
and any request
for
such
information
is
premature
Subject
to
and without
waiver
of the
foregoing
General
and Specific
Objections
Eight
Mile
will
produce relevant and discoverable
documents
at the
appropriate
time
DATED
March 21 2008
Respectfully
submitted
Richard
Busch
Street Street
TN
Bar
No
014594
1100 Union 315 Union
Plaza
Nashville
TN
37201
615
259-3456
rbuschkingballow.com
Howard Hertz Esq P26653
Jay Hertz
Yasso Esq
Schram
P45484
PC
1760
Telegraph
Rd
MS
Suite 300
Bloomfield Hills
48302
248
335-5000
hhertz@hertzschram.com jyassohertzschram.com
Attorneys
for Plaintiffs
14
CERTIFICATE
OF SERVICE
foregoing
The
postage
undersigned
hereby
certifies to
that
the
document
was
served
via
U.S
Mail
pre-paid
and via e-mail
the following
Counsel
Daniel
On
Quick Esq
Wright
behalf
of
Apple
Computer Inc
and Aftermath Records
dlb/a
Aftermath
Dickinson 38525
PLLC
Ave
Entertainment
Woodward
Suite 2000
Bloomfield Hills
MI
48304
248
433-7200
dquickdickinsonwright.com
Kelly
Klaus
Tolles
Esq
Olson LLP
Munger
355 South Grand
Suite 3500
Ave
Los Angeles
CA
90071-1560
213
683-9238
kelly.klausmto.com
this 21st
day of March 2008
15
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