Timebase Pty Ltd v. Thomson Corporation, The

Filing 126

MEMORANDUM in Support re 124 MOTION to Compel Responses to Interrogatories 1 and 7 and Various Document Requests filed by Timebase Pty Ltd. (Hosteny, Joseph) SEALED DOCUMENT RECEIVED IN CLERK'S OFFICE ON 3/16/10. (KT)

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Timebase Pty Ltd v. Thomson Corporation, The Doc. 126 Att. 5 EXHIBIT 6 Dockets.Justia.com JENNIFER ROBBINS M. 612-349-871 1 July 8,2009 VIA E-MAIL AND U.S. MAIL Kristal S. Stippich, Esq. Gass Weber Mullins LLC 309 North Water Street Milwaukee, W153202 Re: LeMond Cycling, Inc. v. Trek Bicycle Corporation Case No. 08-CV-01010 (RHWJSM) Our File No.: 123595.0000 Dear Ms. Stippich: I write to clarify a couple of points in your July 6 letter regarding the July 2,2009 meet and confer. First, regarding Requests for Admission Nos. 1-9 and the related Interrogatory and Document Request, we are not asking that Trek delineate all documents it intends to use at trial. Our position is simply that Plaintiff is unable to authenticate thousands of pages of documents, produced by third parties to this litigation, without knowledge of what Trek believes the documents purport to be. Second, we indicated that Interrogatory No. 11 is overbroad and unduly burdensome on its face because it seeks all facts in support of Plaintiffs case, which would require a detailed narrative of Plaintiffs case in response. We futher indicated that Trek cannot legitimately assert that it is unaware of the support for Plaintiffs claims and defenses with all of the depositions, expert reports, and other discovery available to Trek in this matter. We will provide a revised response to Interrogatory No. 14 by July 9. We will also provide confirmation to you as soon as possible regarding: (1) the estimated date of the recording of Greg LeMond, Betsy Andreu, and Sidney Bluming; and (2) the production, or identification on a privilege log, of all recordings relevant to this lawsuit. Sincerely, ROBINS, KAPLAN, MILLER & CPRESI L.L.P. Jennifer M. Robbins JMRhsb cc: Ralph A. Weber, Esq. u. A T L A N T A . B O S T O N . L O S A N G E L E S M I N N E A P O L I S N A P L E S

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