/XObject 128 0 R 1) litigators are not sending them. /Type /Page 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." [(Mo)-1.8 (ns)-3.7 (a)-6 (nt)-1.1 (o )]TJ f T* T* >> 1 0 0 1 152.3695068 766 cm )25.903 (1)]TJ Q >> /Length 132 0 R [(c)4 (ont)-2 (a)4 (i)-1.9 (n a)4.5 ( pr)3 (e)-6.7 (c)4.7 (i)-1.9 (se)1.9 ( de)-6.7 (f)3.7 (i)-1.9 (ni)-2.9 (t)-2 (i)-2 (on of)3 ( t)-2 (he)4 ( phr)3.8 (a)3.2 (s)-10.9 (e)4.7 ( a)4 (nd r)-7.7 (e)4.7 (f)3 (e)-5.9 (r)2.9 (e)3.1 (nc)4 (e)4.9 (s )-11.8 (a)3.1 ( va)4.8 (r)3 (i)-11.9 (e)3.1 (t)-11.9 (y)20.7 ( o)-10.7 (f)2.9 ( t)-1.9 (ox)-10 (i)-2 (c)4.7 (i)-2.7 (t)7.9 (y)20 ( )]TJ pD1visp[n5pL3lQtM;-a-VO}]ny]t;pcgj(q =vwVB~dm$ 4H^~#Ead4*KSj:sLGLvBSHr$$UKe;vtT='l6tdfIKq5'H=l#?JzT=A?qjf)$d?RTia&p%NoD]FYD/}@J!>1Za{JZ:LigFmhHgSLI a^xrJgr,6l_. See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). q (25)Tj Q Responding party objects that the request seeks documents already in plaintiffs possession custody or control. >> (19)Tj (9)Tj 1304/1307 (S.D.N.Y., Feb. 18, 2017), the plaintiff requested the production of almost a decade of emails, letters, and marketing materials. Plaintiff objects to Definition No. By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case. Q 0.909091 0 0 0.909091 6.020233 36 cm Civil Investigative Demand Number 13009 was not an investigation, it was a document request. 2. /DR 12 0 R (2)Tj 44.77 0 Td Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). (23)Tj 5. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrase "CID investigation," unless it is intended to limit the definition of "statement" to any comment, observation, remark, observation, or affirmation, whether in written or oral form, made by a third party to Plaintiff during the Civil Investigative Demand Number 13009 investigation. 51 0 obj /Count 20 104.03 792 0.83 -792 re Merely said, the Sample Objections To Request For Production Of Documents Pdf Pdf is universally compatible taking into consideration any devices to read. BT Q All documents reflecting any statement of a third party to the DOJ and signed and/or adopted, formally or informally, by those third parties. Q 1028. See my blog " Make Sure you are aware of the New Document Response Requirements" for an updated analysis. [( Mo)-1.8 (ns)-2 (a)3.1 (nt)-2 (o i)-1.1 (nc)3.1 (or)2.9 (por)3.9 (a)3.2 (t)-1.1 (e)3.1 (s )-2 (b)-20.1 (y)19 ( )-9.9 (r)3.8 (e)4 (f)-7.7 (e)4.7 (r)2.2 (e)4 (n)-9.1 (c)3.9 (e)-5.9 ( G)1.9 (e)3.1 (ne)4 (r)-6 (a)3.1 (l)-2 ( O)2 (bj)-2 (e)4 (c)4.8 (t)-1.9 (i)-2.9 (ons )-2 (1-)1.8 (6 )-9.9 (he)3.1 (r)3 (e)4.8 ( a)3.1 (s i)-2 (f)2 ( )]TJ T* << Each response, if any, is subject to any and all objections as to competence, relevance, materiality, propriety, and admissibility, and any and all 36 -24 Td /TT1 12 Tf /MediaBox [0 0 612 792] Q -39.96 -12 Td -29.975 -24 Td [(A)1.1 (D)2 (M)4 (IT)-4.8 (S)]TJ The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection.
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