Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 18 of 34
Defendant’s possession, custody, or control; is publicly available; is already in Plaintiffs’ possession, care, custody, or control; or is generally available to Plaintiffs.
6. Defendant generally objects to the Document Requests to the extent that the information sought is not identified with sufficient particularity.
Te Defendant objects to the definition of “Documents” to the extent that it seeks the production of things beyond the scope of Rule 1.280 of the Florida Rules of Civil Procedure. Defendant further objects to the definition of “Documents” to the extent that it seeks “electronic data as well as application metadata and system metadata” and “inventories and rosters of your information technology (IT) systems — e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servicers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools
and protocols” as overly broad and unduly burdensome.
RESPONSES TO REQUESTS
1. Copies of any and all documents reflecting or relating to any and all occasions on which you have been physically present on Little Saint James Island including but not limited to your visit to Little Saint James Island, as described in paragraph 3 of the sworn Declaration of Alan M. Dershowitz.
RESPONSE:
Subject to and without waiving the General Objections, Defendant responds that he wil! produce
all responsive, non-privileged documents currently in his possession, custody or control relating
to the sole occasion on which Defendant was physically present on Little Saint James Island.
HOUSE_OVERSIGHT_014101