Lipari Second Motion to Compel Production of Discovery Request ...

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RESPONSE:The GE defendants object to Request J on the grounds that it seeks attorney clientcommunications and work jjf(lciuct materials. The OR defendants further object to Request .3 onthe grounds that it seeks documentsfrom an entity that is not a party to this litigation.4, Documents related to the defendants' representation by the law finn Husch &Eppenbcrger, LLC including Husch & Eppenberger, LLC's board meeting minutes, internalinvestigations, correspondence, attachments. agreements, emails and phone communications andlogs for all minutes of meetings of officers, attorneys, employees, representatives,and agents forHusch & Eppcnbcrger, LLC concerning the representation of GE, GE Capital, OETransportation, GE Medical, GHX and any related entities) representatives or agents in mattersconcerning Medical Supply Chain: Inc., Samuel Lipari, Brct Landrith and Dennis Hawver.RESPONSE:The GE defendants object to Request 4 on the grounds that it seeks attorney clientcommunications and work product materials The GE defendants further object to Request 4 onthe grounds that it seeks documentsfrom an entity that is not 9.. party to this litigation.S. Documents related to the defendants' representation by the law finn ArnoId &Porter and Husch & Eppenberger, LLC including correspondence, attachments, agreements,cmails and phone communications and logs for all minutes of meetings of officers, attorneys,employees, representatives, and agent:'> exchanged between Arnold & Porter and Rusch &Eppenberger, LLC concerning the representation of OE~ GE Capital, GE Transportation, GEMedical, GI-IX and any related entities, representativesor agents in matters concerning MedicalSupplyChain, Inc., Samuel Lipari, Brct Landrith and Dennis Hawver.RESPONSE:The GE defendants object to Request 5 on the grounds that it seeks attorney clientcommunications flt1dwork product materials, The GE defendants further object to Request 5 onthe grounds that it seeks documentsfrom an entity that is not a. party to this litigation,4
6. Documents related to the defendants' coordination of representation by the lawfirm Arnold & Porter and Husch & Eppenberger, LLC with attorneys and corporatecounselrepresenting US Bank NA, US Bancorp, The Piper Jaffray Companies including correspondence,attachments, agreements, ernails and phone communications and logs for all minutes of meetingsof officers, attorneys, employees, representatives, and agents exchanged between the defendantsand their counsel with Shugart Thomson & Kilroy and their client's corporate counsel in mattersconcerning Medical Supply Chain, Inc., Samuel Lipari, Bret Landrith and Dennis Hawver,RESPONSE:The GE defendants object to Request 6 on the grounds that it seeks attorney clientcommunications and work product materials. The GE defendants further object to Request 6 allthe grounds that it seeks documents from an entity that is not a party to this litigation.7. Documents related to the defendants" coordination of representation by the lawfirm Arnold & Porter and Rusch & Eppenberger, LLC communications with the law firmsSeyfarth Shaw, Jenner & Block, Miller Shakman & Beem, Bryan Cave, Novak & Macey, LordBissel & Brook) Cummins & Cronin, and Jenkins & Gilchrist including correspondence,attachments, agreements, entails and phone communications and logs for all minutes of meetingsof officers, attorneys, employees, representatives, and agents exchanged between the defendantscounsel and the above named law firms in matters concerning McCook Metals, MichiganAvenue Partners, Michael Lynch, Medical Supply Chain, Inc., Samuel Lipari, Bret Landrith andDennis Hawver.RESPONSE;The GE defendants object to Request 7 on the grounds that it seeks attorney clientcommunications and work product materials. The GE defendants further object to Request 7 onthe grounds that it seeks documents from an entity that is not a party to this litigation.09~JIJriJIl 5
Page 1 and 2: IN THE CIRCUIT COURT OF ,JACKSON CO
Page 3: RESPONSE:The GE defendants object t

Lipari Second Motion to Compel Production of Discovery Request ...

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