1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STEIN & ASSOCIATES Michael D. Stein (SBN 132540) 5235 West Allen Street Suite 200 Los Angeles, CA 90067 Tel: (213) 555-0994 Fax: (213) 555-0995 Attorneys for Defendant B-2 VIDEO INCORPORATED UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SCOTT ALAN WOODWARD, Plaintiff, vs. B-2 VIDEO INCORPORATED, a Missouri corporation; and DOES 1 through 20 inclusive, Defendants. ) ) ) ) )))))) ))) )) ) ) ) ) )) Case No.: DEFENDANT B-2 VIDEO INCORPORATED’S RESPONSES TO PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR ADMISSIONS ) PROPOUNDING PARTY: Plaintiff SCOTT ALAN WOODWARD RESPONDING PARTY: Defendant B-2 VIDEO INCORPORATED SET NO.: One 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant B-2 Video Incorporated (“Defendant”) has not yet completed investigation of the facts relating to this case, has not completed discovery and has not completed its preparation for trial. Accordingly, the following responses are based upon information known at this time and are given without prejudice to Defendant’s rights to produce subsequently discovered evidence and facts, and to add to, modify or otherwise change or amend the responses herein. REQUEST NO. 1: Admit that YOU (For the purpose of these requests for admissions, the term “YOU” shall mean defendant B-2 Video Incorporated, its divisions, subsidiaries, affiliated entities, predecessors and successors in interest, and all officers, servants, employees, agents, representatives, persons or entities acting on its behalf or on behalf of any division, subsidiary or affiliated entity, whether individually or collectively) did not implement a reduction in force policy because of economic conditions in the 2002 calendar year. RESPONSE TO REQUEST NO. 1: Defendant objects to this Request on the grounds that it is vague, ambiguous and unintelligible. Without waiving the foregoing objections, Defendant responds as follows: Denied. REQUEST NO. 2: Admit that the only employees terminated from the unit in which PLAINTIFF (For the purpose of these requests for admissions, 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the term “PLAINTIFF” shall mean Scott Alan Woodward) worked were PLAINTIFF and Greg Jones. RESPONSE TO REQUEST NO. 2: Admitted. REQUEST NO. 3: Admit that the May 9, 2002 memorandum to PLAINTIFF attached hereto as Exhibit “A” is authentic. RESPONSE TO REQUEST NO. 3: Admitted. DATED: March 31, 2004 STEIN & ASSOCIATES By: _________________________________ Michael D. Stein Attorneys for Defendant B-2 VIDEO INCORPORATED 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss: COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action. My business address is 5235 West Allen Street Suite 200, Los Angeles, CA 90067. On March 31, 2004, I served the foregoing document described as DEFENDANT B-2 VIDEO INCORPORATED’S RESPONSES TO PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR ADMISSIONS on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Peter Crawford, Esq. 27255 Van Buren Road Torrance, California 93627 ___ BY MAIL I deposited such envelope into the Firm’s office mail at Los Angeles, California. I am readily familiar with the Firm’s practice of collection and processing correspondence for mailing. Under that practice, in the ordinary course of business, the mail is affixed with postage thereon fully prepaid and deposited with the U.S. Postal Service in Los Angeles, California on the same day. I am aware that on motion of a party served, service is presumed invalid if the postal cancellation date or the postage meter date is more than one (1) day after the date of deposit for mailing in this affidavit. ___ BY PERSONAL SERVICE I hand delivered such envelope to the offices of the addressee(s) listed above. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made. Executed March 31, 2004 at Los Angeles, California. _____________________________ Harriet Evans