Message: PACER
Thanks Silver ,
this was Sakar response to # 14 that has been rejected by judge today !
See Exhibit C, Interrogatory No. 14. Sakar responded as follows:
Sakar objects to this Interrogatory to the extent that it seeks
production of information or material that is protected from
disclosure by the attorney-client privilege, the work product
doctrine exemption from discovery, the consulting expert
exemption from discovery, the investigative privilege, the
community interest privilege, and/or any other applicable
constitutional, statutory, or common law privilege. Sakar objects
because this interrogatory is overly broad, unduly burdensome,
irrelevant and therefore not calculated to lead to the discovery of
admissible evidence when it asks Sakar to identify “all” persons
who were “consulted” or “who provided information.” Sakar
objects to this Interrogatory to the extent that it calls for
information not within Sakar’s possession, custody or control.
See Exhibit J Response No. 14. Leaving aside the fact that Sakar’s interrogatory responses do
not contain any substantive information thereby obviating any argument that the identity of the
persons who provided this non-substantive information is somehow “burdensome,” Sakar’s
allegation that the information is somehow “irrelevant” and “not within Sakar’s possession,
custody or control” is simply beyond the pale. This is but one example of Sakar’s dilatory
approach to discovery, the remainder of which are set forth in greater detail below.
Sakar objects to this Interrogatory to the extent that it seeks
production of information or material that is protected from
disclosure by the attorney-client privilege, the work product
doctrine exemption from discovery, the consulting expert
exemption from discovery, the investigative privilege, the
community interest privilege, and/or any other applicable
constitutional, statutory, or common law privilege. Sakar objects
because this interrogatory is overly broad, unduly burdensome,
irrelevant and therefore not calculated to lead to the discovery of
admissible evidence when it asks Sakar to identify “all” persons
who were “consulted” or “who provided information.” Sakar
objects to this Interrogatory to the extent that it calls for
information not within Sakar’s possession, custody or control.
See Exhibit J Response No. 14. Leaving aside the fact that Sakar’s interrogatory responses do
not contain any substantive information thereby obviating any argument that the identity of the
persons who provided this non-substantive information is somehow “burdensome,” Sakar’s
allegation that the information is somehow “irrelevant” and “not within Sakar’s possession,
custody or control” is simply beyond the pale. This is but one example of Sakar’s dilatory
approach to discovery, the remainder of which are set forth in greater detail below.
7 Recommendations
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