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Response+to+Req.+for+Docs

VIEWS: 236 PAGES: 6

									 1   STEIN & ASSOCIATES
     Michael D. Stein (SBN 132540)
 2   5235 West Allen Street
     Suite 200
 3   Los Angeles, CA 90067
     Tel: (213) 555-0994
 4   Fax: (213) 555-0995
 5   Attorneys for Defendant
     B-2 VIDEO INCORPORATED
 6

 7

 8                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                         FOR THE COUNTY OF LOS ANGELES
10

11
     SCOTT ALAN WOODWARD,             )   Case No.:
12
                                      )
13              Plaintiff,            )   ASSIGNED FOR ALL PURPOSES TO JUDGE
                                      )   JOHN SMITH
14                                    )   Department 27
          vs.
                                      )
15                                    )   DEFENDANT B-2 VIDEO INCORPORATED’S
                                      )   RESPONSES TO PLAINTIFF SCOTT ALAN
16   B-2 VIDEO INCORPORATED, a        )   WOODWARD’S FIRST REQUEST FOR
     California corporation; and      )   PRODUCTION OF DOCUMENTS
17
     DOES 1 through 20 inclusive,     )
18                                    )
                Defendants.           )
19                                    )
                                      )
20                                    )
                                      )
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                                      )
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                                      )
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                                      )
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25              PROPOUNDING PARTY:    Plaintiff SCOTT ALAN WOODWARD
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                RESPONDING PARTY:     Defendant B-2 VIDEO INCORPORATED
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                SET NO.:              One
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                                      1                __________________________________
                                                       RESPONSE TO REQUEST FOR PRODUCTION
 1                Defendant B-2 Video Incorporated (“Defendant”) has not
 2   yet completed investigation of the facts relating to this case,
 3
     has not completed discovery and has not completed its preparation
 4
     for trial.    Accordingly, the following responses are based upon
 5
     information known at this time and are given without prejudice to
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     Defendant’s rights to produce subsequently discovered evidence and
 7
     facts, and to add to, modify or otherwise change or amend the
 8

 9   responses herein.

10   REQUEST NO. 1:

11         All DOCUMENTS relating to or reflecting the facts and
12   circumstances of any discipline of PLAINTIFF or concerning any
13
     alleged misconduct engaged in by PLAINTIFF.
14
     RESPONSE TO REQUEST NO. 1:
15
           Defendant objects to this Request on the grounds that it is
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     vague, ambiguous, overbroad, burdensome and seeks information that
17

18   is both irrelevant and not reasonably calculated to lead to the

19   discovery of admissible evidence.    Without waiving these

20   objections, Defendant responds as follows:    Defendant will produce
21   all documents in its custody, possession or control that are
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     responsive to this Request.
23
     REQUEST NO. 2:
24
           Any and all video and/or audio investigation tapes reflecting
25
     the facts and circumstances of any alleged misconduct engaged in
26

27   by PLAINTIFF.

28   ///

                                      2               __________________________________
                                                      RESPONSE TO REQUEST FOR PRODUCTION
 1   RESPONSE TO REQUEST NO. 2:
 2         There are no documents in Defendant’s custody, possession or
 3
     control that are responsive to this Request.
 4
     REQUEST NO. 3:
 5
           All DOCUMENTS supporting or relating to YOUR Fifth
 6
     Affirmative Defense that “Any and all alleged defamatory
 7
     statements made by Defendants or their agents were true.”
 8

 9   RESPONSE TO REQUEST NO. 3:

10         Defendant objects to this Request on the grounds that it is

11   overbroad and burdensome.    Defendant further objects to this
12   Request on the grounds that it improperly requires Defendant to
13
     permit Plaintiff to discover Defendant’s legal conclusions and
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     theories and thus intrudes on the attorney work-product privilege.
15
     REQUEST NO. 4:
16
           All DOCUMENTS identified in YOUR responses to PLAINTIFF’S
17

18   First Set of Special Interrogatories served concurrently herewith.

19   RESPONSE TO REQUEST NO. 4:

20         Defendant will produce all documents in its custody,
21   possession or control that are responsive to this Request.
22
     REQUEST NO. 5:
23
           All DOCUMENTS identified in YOUR responses to PLAINTIFF’S
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     First Set of Form Interrogatories served concurrently herewith.
25
     ///
26

27   ///

28   ///

                                     3               __________________________________
                                                     RESPONSE TO REQUEST FOR PRODUCTION
 1   RESPONSE TO REQUEST NO. 5:
 2        Defendant will produce all documents in its custody,
 3
     possession or control that are responsive to this Request.
 4

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     DATED:   March 31, 2004      STEIN & ASSOCIATES
 6

 7
                                  By: _________________________________
 8
                                               Michael D. Stein
 9                                Attorneys for Plaintiff
                                  SCOTT ALAN WOODWARD
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                                     4                 __________________________________
                                                       RESPONSE TO REQUEST FOR PRODUCTION
 1                                VERIFICATION
 2        PETER L. ORNELLAS declares:
 3
                 1.   I am the Vice-President of Operations of defendant
 4
     B-2 Video Incorporated (“Defendant”) in the above-captioned action
 5
     and am authorized to make this Verification on Defendant’s behalf.
 6
                 2.   I have read the foregoing “DEFENDANT B-2 VIDEO
 7
     INCORPORATED’S RESPONSES TO PLAINTIFF SCOTT ALAN WOODWARD’S FIRST
 8

 9   REQUEST FOR PRODUCTION OF DOCUMENTS” (“the Response”) and know its

10   contents.   I am informed and believe that the matters set forth in

11   the Response are true and accurate, and on that ground I allege,
12   to the best of my knowledge and information, that the matters
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     therein stated are true and accurate.
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                 I declare under penalty of perjury under the laws of the
15
     State of California that the foregoing is true and correct and
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     that this Verification was executed on March 31, 2004 at Los
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18   Angeles, California.

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20                                   ________________________________
                                            Peter L. Ornellas
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                                      5              __________________________________
                                                     RESPONSE TO REQUEST FOR PRODUCTION
 1                              PROOF OF SERVICE

 2
     STATE OF CALIFORNIA        )
 3                              )      ss:
     COUNTY OF LOS ANGELES      )
 4
               I am employed in the County of Los Angeles, State of
 5   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
 6   Suite 200, Los Angeles, CA 90067.
 7               On March 31, 2004, I served the foregoing documents
 8   described   as DEFENDANT B-2 VIDEO INCORPORATED’S RESPONSES TO
     PLAINTIFF   SCOTT ALAN WOODWARD’S FIRST REQUEST FOR PRODUCTION OF
 9   DOCUMENTS   on the interested parties in this action by placing a
     true copy   thereof enclosed in a sealed envelope addressed as
10   follows:
11                    Peter Crawford, Esq.
                      27255 Van Buren Road
12
                      Torrance, California      93627
13

14        ___    BY MAIL

15                  I deposited such envelope into the Firm’s office
     mail at Los Angeles, California. I am readily familiar with the
16   Firm’s practice of collection and processing correspondence for
     mailing. Under that practice, in the ordinary course of business,
17
     the mail is affixed with postage thereon fully prepaid and
18   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,
19   service is presumed invalid if the postal cancellation date or the
     postage meter date is more than one (1) day after the date of
20   deposit for mailing in this affidavit.
21        ___    BY PERSONAL SERVICE
22
                    I hand delivered such envelope to the offices of
23   the addressee(s) listed above.

24             I declare under penalty of perjury under the laws of the
     State of California that the foregoing is true and correct.
25   Executed March 31, 2004 at Los Angeles, California.
26

27
                                             _____________________________
28                                                  Harriet Evans

                                       6                  __________________________________
                                                          RESPONSE TO REQUEST FOR PRODUCTION

								
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