In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 2913

LETTER addressed to Judge Shira A. Scheindlin from Nicholas G. Campins dated 3/10/09 re: The City of New York writes to request the Court's assistance in resolving a discovery dispute regarding its obligations, if any,to further respond to 11 sets of unduly burdensome contention discovery served by defendants on 11/18/08 and 11/19/08, see Exhibits A1-A11, which the City responded to on 12/18/08 and 12/19/09, see Exhibits B1-B11. Document filed by All Plaintiffs. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit)Associated Cases: 1:00-cv-01898-SAS-DCF, 1:04-cv-03417-SAS(mro) (Additional attachment(s) added on 12/15/2009: #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit) (mro).

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In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation Doc. 2913 Att. 1 City of New York v. Amerada Hess, et al., Case No. 04-CV-3417 (SDNY) In re MTBE Products Liability Litigation, MDL 1358 TABLE OF EXHIBITS EXHIBIT A A1 A2 A3 A4 A5 A6 DESCRIPTION Contention Discovery Certain Defendants' First Set of Interrogatories and Document Requests Regarding Punitive Damages Citgo Defendants' First Set of Company-Specific Interrogatories and Document Requests Defendants' Contention Interrogatories and Document Requests on Causation, Theories of Liability and Apportionment of Damages Atlantic Richfield Company's First Set of Interrogatories and Requests for Production of Documents to Plaintiff City of New York BP Products of North America Inc.'s First Set of Interrogatories and Requests for Production of Documents to Plaintiff City of New York Defendants El Paso Merchant Energy-Petroleum Company's and Coastal Eagle Point Oil Company's First Set of Company-Specific Interrogatories and Document Requests Defendant Gulf Oil Limited Partnership's Requests for Admission, Interrogatories and Requests for Production to Plaintiff City of New York The Premcor Refining Group Inc.'s First Set of Interrogatories and Requests for Production of Documents to Plaintiff City of New York Defendants Sunoco, Inc. and Sunoco, Inc. (R&M)'s First Set of Company-Specific Interrogatories and Document Requests Total Petrochemicals USA, Inc's First Set of Interrogatories and Requests for Production of Documents to Plaintiff City of New York 11/18/08 11/18/08 11/19/08 11/19/08 11/19/08 11/19/08 DATE A7 11/19/08 A8 A9 A10 11/19/08 11/19/08 11/19/08 Page 1 of 3 Dockets.Justia.com A11 Valero Defendants and Ultramar Defendants' First Set of Interrogatories and Requests for Production of Documents to Plaintiff City of New York Responses and Objections Plaintiff City of New York's Responses and Objections to Certain Defendants' First Set of Interrogatories and Document Requests Regarding Punitive Damages Plaintiff City New York's Responses and Objections to Citgo Defendants' First Set of Company-Specific Interrogatories and Document Requests Plaintiff City of New York's Responses and Objections to Defendants' Contention Interrogatories and Document Requests on Causation, Theories of Liability and Apportionment of Damages Plaintiff City of New York's Responses and Objections to Atlantic Richfield Company's First Set of Interrogatories and Requests for Production of Documents Plaintiff City of New York's Responses and Objections to BP Products North America Inc.'s First Set of Interrogatories and Requests for Production of Documents Plaintiff City of New York's Responses and Objections to Defendants El Paso Merchant Energy-Petroleum Company and Coastal Eagle Point Oil Company's First Set of Company-Specific Interrogatories and Document Requests Plaintiff City of New York's Responses and Objections to Defendant Gulf Oil Limited Partnership's Requests for Admission, Interrogatories and Requests for Production Plaintiff City of New York's Responses and Objections to the Premcor Refining Group Inc.'s First Set of Interrogatories and Requests for Production of Documents Plaintiff City of New York's Responses and Objections to Defendants Sunoco, Inc. and Sunoco, Inc. (R&M)'s First Set of CompanySpecific Interrogatories and Document Requests Plaintiff City of New York's Responses and Objections to Total Petrochemicals USA, Inc.'s First Set of Interrogatories and Requests for Production of Documents 11/19/08 B B1 12/18/08 B2 12/18/08 B3 12/19/08 B4 12/19/08 B5 12/19/08 B6 12/19/08 B7 12/19/08 B8 12/19/08 B9 12/19/08 B10 12/19/08 Page 2 of 3 B11 Plaintiff City of New York's Responses and Objections to Valero Defendants and Ultramar Defendants' First Set of Interrogatories and Requests for Production of Documents Meet and Confer Correspondence Email from N. Campins to Counsel Re: Request for Extension for the City's Response to Contention Interrogatories Email from J. Pardo to N. Campins Re: Request for Extension Email from N. Campins to J. Pardo Re: Request for Extension Letter from J. A. Langan to S. Amron Re: Encl. List of Discovery Responses Letter from N. Campins to J.A. Langan Re: Contention Discovery Letter from J. A. Langan to N. Campins Re: Contention Discovery Excerpt from October 31, 2007 MDL Status Conference Case Management Order # 31 12/19/08 C C1 C2 C3 C4 C5 C6 D E F 12/15/08 12/16/08 12/17/08 3/3/09 3/4/09 3/6/09 11/6/07 3/4/09 Letter from G. Weintraub to S. Amron Re: Encl. Citgo's Second Amended Responses and Objections to City of New York's Fourth Set of Interrogatories Examples of Specific Objections Example of Objection to Request as Based on Invalid Legal Assumptions Example of Objection to Request as Seeking Attorney Work Product Example of Objection to Request as Seeking information within the Control of Defendants Example of Objection to Definitions as Vague and Ambiguous 12/18/08 12/19/08 G G1 G2 G3 G4 Page 3 of 3

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