Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA287527
`ESTTA Tracking number:
`06/03/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91188416
`Plaintiff
`D-Col, Inc.
`Patrick J. Stolmeier
`D-Col, Inc.
`219 East Craig Place
`san antonio, TX 78212
`UNITED STATES
`patrick@stolmeierlaw.com
`Motion to Compel Discovery
`Patrick J Stolmeier
`patrick@stolmeierlaw.com
`/Patrick J Stolmeier/
`06/03/2009
`ltr.pdf ( 1 page )(131181 bytes )
`discovery.pdf ( 37 pages )(169121 bytes )
`discoverysignature01.pdf ( 1 page )(264191 bytes )
`discoverysignature02.pdf ( 1 page )(79493 bytes )
`MTN to Compel.pdf ( 2 pages )(57643 bytes )
`compelsignature.pdf ( 1 page )(149117 bytes )
`oraldeposition01.pdf ( 1 page )(174163 bytes )
`oraldeposition02.pdf ( 1 page )(74658 bytes )
`
`
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA287527
`ESTTA Tracking number:
`06/03/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91188416
`Plaintiff
`D-Col, Inc.
`Patrick J. Stolmeier
`D-Col, Inc.
`219 East Craig Place
`san antonio, TX 78212
`UNITED STATES
`patrick@stolmeierlaw.com
`Motion to Compel Discovery
`Patrick J Stolmeier
`patrick@stolmeierlaw.com
`/Patrick J Stolmeier/
`06/03/2009
`ltr.pdf ( 1 page )(131181 bytes )
`discovery.pdf ( 37 pages )(169121 bytes )
`discoverysignature01.pdf ( 1 page )(264191 bytes )
`discoverysignature02.pdf ( 1 page )(79493 bytes )
`MTN to Compel.pdf ( 2 pages )(57643 bytes )
`compelsignature.pdf ( 1 page )(149117 bytes )
`oraldeposition01.pdf ( 1 page )(174163 bytes )
`oraldeposition02.pdf ( 1 page )(74658 bytes )
`
`
`
`_D-Cal, Inn‘.
`219 E. Craig Pines
`San Antonia; Tfliifls 178212
`rszephans: 21 0/227-3612
`Fax: 210/327-3621
`
`
`
`June 2, 2009
`
`Bill Nash
`
`Atterney at Law
`Western Centre
`112 E. Pecan Street, Suite 2400
`San Antenie, Texas 73205
`
`Re:
`
`D-Ce], Ine. vs. Terry Ynnng
`Opposition Ne. 91 133416
`Serial Nu. 77540351
`
`Dear Mr. Nash:
`
`Enelesed find D-Cal, Inefs Martian tn Cnmpel Diseevery from Terry L. ‘(sung and far
`Sanctinns.
`
`‘are any questiens, please enntact me.
`
`
`
`Sheuld yen
`
`
`
`Very truly years
`
`P,a’1;1'iek J. Stnlmeier
`"Fer D-Cel, Ina.
`
`e.e.
`
`Trademark Trial and Appeal Beard
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Trademark Trial and Appeal Board
`
` !!∀∀#!∃
`Opposition No. 91188416
`Serial No. 77540851
` %%&#∋∀&!
`
`( ) ∗
`D-Col, Inc.
`
`V.
`+
`
`, −.)/0
`Young, Terry L.
`
`
`
`INTERROGATORIES, REQUEST FOR PRODUCTION OF
`DOCUMENTS AND THINGS ADMISSIONS AND DISCLOSURE
`
`
`
`
` !! ∀ #∃
` %& ∃ #
` ∋ & %
` (∋) !# ∗#+!∗
` +,∋%− +
`TO:
`Terry L. Young, 20770 N Hwy 281, Suite 108, San Antonio, Texas 78258-7500, e-mail -
`)&. /,) 0,
`srt3000@msn.com.
`
`
`
`
`
`
`
`Please take notice that pursuant to the Rules of Procedure, D-Col, Inc. serves the attached
`
`
`
`
`
`
`
`
`
`
`
`Interrogatories, Request for Production of Documents and Things, Admissions and Disclosure
`
`
`
`
` !∀
` #∃%%∃&∋( #)∗+ ∗∃)+
`
` ,%)#−)%−∃∃
`propounded to Terry L. Young, 20770 N Hwy 281, Suite 108, San Antonio, Texas 78258-7500.
`
`∀
` .
` (
`
`(
`
`
`You are hereby instructed to answer the following interrogatories separately, fully, in
`
`(
`
`
`
`
`writing, and under oath pursuant to the Rules of Procedure.
`
`∀
`
` ( ./
`
`
`
`
`Your failure to make timely answers may subject you to sanctions as provided in the Rules
`
`of Procedure.
`
`
`
`
`0
`
`
`
`
` (
`
`Furthermore, demand is made for the supplementation of your answers to these
`
`
`
`
`
`
`
` .
`Interrogatories, Request for Documents and Things, Admissions and Disclosure as required by the
`
`Rules of Procedure.
`
`
`
`
`0
`
`
`
`
`
`
`
`
`Furthermore, produce or permit D-Col, Inc., to inspect and copy or reproduce the items
`
`
`
`
`
`
`
`requested in the Request for Production of Documents and Things.
`
`
`
`D-Col, Inc.
`#∗12
`219 E. Craig Place
`+
`
` ,%)#∗#
`San Antonio, Texas 78212
`3#∗∃4##%56∗#
`(210) 227-3612
`3#∗∃4##%56#∗30 74
`(210)227-3621 (FAX)
`
`
`
`BY:
`8∀9
`
`
`
`
`
`D-Col, Inc.
`
`CERTIFICATE OF SERVICE
` 1
`
`
`
` .
` (
` !∀
`
`
(
`I certify that a true copy of the above was served on Terry L. Young in accordance with the
`
`: + ;
`I certify that a true copy of the above was served on Terry L. Young in accordance with the
`
`: + ;
8
`
` <
`
` <
#6#∃∃1
`United States Patent and Trademark Office Trial and Appeal Board Rules on March 26, 2009.
`
`=================================
`
`
`United States Patent and Trademark Office Trial and Appeal Board Rules on March 26, 2009.
`
`=================================
`
`
`D-Col, Inc.
`
`DEFINITIONS AND INSTRUCTIONS
`
`
`
`
` >
`>>
`> ? ≅
` !
`
`As used herein, the terms "you", "your" and “Defendant” shall refer to Terry L.
`a.
`∀
` #∃%%∃&∋( #)∗+ ∗∃)+
`
` ,%)#−)%−∃∃
`
`Young, 20770 N Hwy 281, Suite 108, San Antonio, Texas 78258-7500, and the attorneys, agents,
`
`
`
`.
`
`
`
`
`
`
` .
`and all other natural persons or business or legal entities acting or purporting to act for or on behalf
`
` !∀
` #∃%%∃&∋( #)∗+ ∗∃)+
`
` ,%)#−)%−∃∃(
`of Terry L. Young, 20770 N Hwy 281, Suite 108, San Antonio, Texas 78258-7500, whether
`authorized to do so or not.
`
` Β
`
`
`
`
`
`
` >
`
>
(
`
`
`
`
`.
`The term "documents" shall mean all writings of every kind, source, and
`b.
`
` .
`
`
`
`
`
`
`
`
`
`( .
`
`authorship, both originals and all nonidentical copies thereof, in your possession or known by you
`
` ,
`( (
`
`
` .
`
`
`to exist, irrespective of whether the writing is one intended for or transmitted internally by you, or
`
`
`
`
`
`
`
(
`
`
`intended for or transmitted to any other person or entity, including without limitation any
`
`
`
`
`intended for or transmitted to any other person or entity, including without limitation any
`
`
`
`
`
`government agency, department, administrative entity, or any private entity, or any person.
`
`
`
(
`
`
`
`
`
`.
`
`In accordance with the Rules of Procedure, a document is deemed to be in your
`
`
`
`
`
`
`
`
`
`
`
`
`
`possession, custody or control if you either have physical possession of the item or have a right to
`
`
`
`
`
`
`
` (
`
`
`
`
`possession of the item that is equal or superior to the person who has physical control of the item.
`
`
`
`
`
`The term shall include e-mails, computer generated and stored content, material and
` ( (
`
`
`
`
`
`
`data, handwritten, typewritten, printed, photocopied, computer generated, computer stored,
`
`
`
`
`
`
` (
` .
`
`photographic, or recorded matter. It shall include communications in words, symbols, pictures,
`
`
`
`
`
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`
.
`
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`
`
`
`sound recordings, films, tapes, and information stored in, or accessible through, computer or other
`
`
`
`
`
` (
` Χ
`
`
`
`information storage or retrieval systems, together with the codes and/or programming instructions
`
`
`
0
`
`
`
`
`and other materials necessary to understand and use such systems. For purposes of illustration and
`
`
`
`
`
`
`
`and other materials necessary to understand and use such systems. For purposes of illustration and
`
`
`
9 ∆ ∆ ∆ ∆
`
`
∆
`not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements;
`.
`
`not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements;
`.
`
`
`
`.
` , ∆.
`
`∆.
`
∆. ∆
`bills, statements, and other records of obligations and expenditures; books; brochures; bulletins;
`
`bills, statements, and other records of obligations and expenditures; books; brochures; bulletins;
`
∆
`
`
`
` ∆
( ∆
`calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings;
`
`calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings;
`
∆
.
`
`∆
`
`∆
∆
`
` ∆
`
∆
`
` . (∆
`check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws;
`
`
`
∆
`
`
∆
` ∆
`∆
` ∆
`corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries,
`∆ ∆ ∆
` ∆
`
∆ /
` .
` .
`
`drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit
`
`
`
`
`
∆ ∆
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`
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`and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of
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`
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`and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of
`
`
`
`
`
` ∆ ∆
`
`
`
`
`telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any
`
`
` ∆ ∆ .
`
`∆
` ∆
`
∆ ∆ ∆
`persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press
` ∆ 3
`persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press
` ∆ 3
.
.
`
`
`
`
(
4∆
`releases; printed matter (including published books, articles, speeches, and newspaper clippings);
`
`releases; printed matter (including published books, articles, speeches, and newspaper clippings);
`
` ∆
`∆
`
`
`
`
`purchase orders; records; records of administrative, technical, and financial actions taken or
`
` ∆
`∆
` .
`,
`
`
` ∆
∆
`recommended; reports; safety deposit boxes and contents and records of entry; schedules; security
` ∆
` ∆
`.
` ∆ (∆
`
`agreements; specifications; statement of bank accounts; statements, interviews; stock transfer
` ∆
`
`
`
`
`
`ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries,
`
`
`
`
`
`
` ∆
`conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions;
`
`
`
`
`
`
`
`summaries, notes, and other records and recordings of any conferences, meetings, visits,
` (
`
`
`
` ∆ ∆
`
`
`
`statements, interviews or telephone conversations; telegrams; teletypes and other communications
`
`
∆
`
` ∆: ∆(
` ∆
` (
`sent or received; transcripts of testimony; UCC instruments; workpapers; and all other writings, the
`
`
`(
`
`
`
` (
` ./
`
`contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the
`
`
`particular discovery requested.
`
`>
` >9 >
` >
`
`
`
`"Person": The term "person" shall include individuals, associations, partnerships,
`c.
`
`
`
`
`
`
`
` (
`
`.
`
`
`corporations, and any other type of entity or institution whether formed for business purposes or
`
`
`
`any other purposes.
`
`
`d.
`
`> >
`>
` >9
`"Identify" or "Identification":
`
`
`
`3∗4 Ε
`
` > >
`>
` >
`
`(1) When used in reference to a person, "identify" or "identification" means to
`
`
`
`(
`
`(
`state his or her full name, present or last known residence address, present or last known
`.
` .
`business address and telephone number.
`
`3#4 Ε
`.
`
`
`
`
`
`(2) When used in reference to a public or private corporation, governmental
`
`
`
` > >
`>
` >
`
`entity, partnership or association, "identify" or "identification" means to state its full name,
`
`
`( .
`
`
`
,
`present or last known business address or operating address, the name of its chief executive
`
`
` .
`officer and telephone number.
`
`354 Ε
`
`
> >
`>
`>
` >
`(3) When used in reference to a document, "identify" or "identification" shall
`
`
`
`( 9
`include statement of the following:
`
`34
`(a)
`
`
`
`
`
`
∆
`the title, heading, or caption, if any, of such document;
`
` . 34 34
`
`the title, heading, or caption, if any, of such document;
`
` . 34 34
`
` .
`
` ∆
`3.4
`the identifying number(s), letter(s), or combination thereof, if any;
`(b)
`
`
`
. 34 34
`
`
` .
`
`and the significance or meaning of such number(s), letter(s), or combination
`
`
`
`
`
`
`
`thereof, if necessary to an understanding of the document and evaluation of any
`
`
`
`
`
` ∆
`claim of protection from discovery;
`
`
`
`
∆
`
`
`3
`
`
`3
4
`the date appearing on such document; if no date appears thereon, the
`(c)
` (
`
`
`,
` (
`the date appearing on such document; if no date appears thereon, the
`(c)
` (
`
`
`,
` (
`answer shall so state and shall give the date or approximate date on which such
`
`
( ∆
`document was prepared;
`
` .
`
`
`document was prepared;
`
` .
`
`
`
`
`34
`the number of pages and the general nature or description of such
`(d)
`
`
3 (
`
`
`
`
4(
`document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with
`
`document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with
`
`
` .
`
`.
∆
`sufficient particularity so as to enable such document to be precisely identified;
`
`
`sufficient particularity so as to enable such document to be precisely identified;
`
`
`
` (
`
`
∆
`3 4
`the name and capacity of the person who signed such document; if it
`(e)
`(
` (
`
`
`
`
`was not signed, the answer shall so state and shall give the name of the person or
`
` (
` ∆
`persons who prepared it;
`
`
`3 4
`the name and capacity of the person who signed such document; if it
`(e)
`(
` (
`
`
`
`
`was not signed, the answer shall so state and shall give the name of the person or
`
` (
` ∆
`persons who prepared it;
`
`
`
`
`(
`
`
(
`34
`the name and capacity of the person to whom such document was
`(f)
`
`34
`the name and capacity of the person to whom such document was
`(f)
`
`
`
`
`
`addressed and the name and capacity of such person, other than such addressee, to
`(
`
`
`
`
`( ∆
`whom such document, or a copy thereof, was sent; and
`
`34
`(g)
`or custodians.
`
`
`
`
`
`
`
`
`
`
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`the physical location of the document and the name of its custodian
`
`:
`
`
`
`3Φ4
`Unless a specific date or dates is set forth in any specific question herein,
`(4)
`
`
` . (
`
`
`
`
`you are directed that each question shall be answered for the period of time up to and
`
`including the present date.
`
`>+ 9>
`
`(
`
`
`
`
`"Settlement:," as used herein, means an oral or written, disclosed or undisclosed
`e.
` .
`
>
`agreement, bargain, contract, settlement, partial settlement, limited settlement, "arrangement,
`> >> >
`
`agreement, bargain, contract, settlement, partial settlement, limited settlement, "arrangement,
`> >> >
`
`
`
`
`"deal", "understanding," loan arrangement, credit arrangement, contingent settlement, limitation on
`
`
` .
`/
`
` .
`. (
`
`the amount of liability or judgment, or a promise by or between plaintiffs and any defendants or
`. ( ( .
` 34 (
`between any defendants herein whereby plaintiffs or defendant(s) have in any way released
`
`
` (
`
`
`
`
`
`
`
`
`compromised, in whole or in part, directly or indirectly, or agreed to do so in the future, any of the
`
`
` ( ( .
`
`
`.
`
`
`matters in controversy in this lawsuit whether before, after or during trial or before or after any
`
`
`
`/
`/
`
`jury verdict is returned herein or a judgment is entered or rendered herein.
`
` > >
`
`
`
`
`
`The term "settlement" is also meant to include any resolution of the differences
`. ( 34.
`
`
`
`
`between the plaintiffs and defendant(s) by loan to the plaintiffs or any other device
`(
. (
`
`
`
` /
`which is repayable in whole or in part out of any judgement the plaintiffs may
`
`
`
`
` /
`which is repayable in whole or in part out of any judgement the plaintiffs may
`
` 34
`recover against defendant(s).
`
` > >
`
>< >
`The term "settlement" shall also include "Mary Carter Agreements" as that term is
`used under Federal Law.
` 0 !(
`
`
`The term "settlement" shall also include "Mary Carter Agreements" as that term is
`used under Federal Law.
` 0 !(
`
`
`INTERROGATORIES AND REQUEST FOR PRODUCTION
`
` ∃+
`
`
` .
`INTERROGATORY NO. 1: State the date and location of, and identify by name, address and
`
` .
`
`
(
./
`
`telephone number of each person present, including Defendant, when the subject matter related to
`
8 ,
`
`
`
`
`
`(
`inmates incarcerated in the Bexar County Detention Center acquiring the skin infection known as
`<+
`
` Β
`
`
` Β
`
`<+
`(
`MRSA, colonization and decolonization of MRSA, and the name D-Col was first discussed, and
` ( ( .
`
`
`state what was said by each person that you identified.
`
`ANSWER:
` 29
`
`
∃
`
`
`
`
`RE§ QUEST FOR PRODUCTION NO. 1: Produce copies any and all documents, items, and
`
`
`
`
`materials, including electronically generated or stored, airline iteneries, cancelled checks, airline
`
`
`
`
`
`(
Γ
`tickets, airline reservations and credit card receipts that relate to a trip you took with Patrick J.
`+
` Γ
` <
` . & (< ,
`tickets, airline reservations and credit card receipts that relate to a trip you took with Patrick J.
`+
` Γ
` <
` . & (< ,
`
`
`
` Η
`
`Stolmeier and John Reiner, M.D. to Albuquerque, New Mexico for the purpose to evaluate Z-Coil
`
`
`
`footwear.
`
`
`(
`
`RESPONSE:
`
`
` +
`
`
` .
`INTERROGATORY NO. 2: State the date and location of, and identify by name, address and
`
` .
`
` (
` ∋ Ι
`((
`telephone number of each person present when the names D-Col and Handi Glow were first said,
`
`
` (
`
` ∋ Ι
`(
`and state the name of the person who first said the name D-Col and Handi Glow.
`
`ANSWER:
` 29
`
` . +
`
`
` .
`INTERROGATORY NO. 3: State the date and location of, and identify by name, address and
`
` .
`
` (
`
`
`
`
`
`
`telephone number of each person present when you contend that you hit upon the idea to call your
`
`
` ∋ Ι
`( ( ( .
`
`
`alleged product D-Col and Handi Glow, and state what was said by each person that you identified.
`
`ANSWER:
` 29
`
` 3 .
`
`
`
`
`INTERROGATORY NO. 4: Identify by name, type and description of each product you are
`
`(
`
`
`
`
`
`
`
` ∋
`referring to when you contend you hit upon the idea to call your alleged product D-Col and Handi
`Glow.
`Ι
`(
`
`ANSWER:
` 29
`
` ∗ +
`
`
` .
`INTERROGATORY NO. 5: State the date and location of, and identify by name, address and
`
` .
`
`
(
`
`
`
`
` ((
`
`
`
`telephone number of any person, including Defendant, who you contend was working on products
`
`
` .<+
` .
`
. #∗#∃∃% (
(
` .
` .
`to combat MRSA for several years before December 21, 2007, and state what was done by each
`
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`
`person that you identified.
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`ANSWER:
` 29
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`RE§ QUEST FOR PRODUCTION NO. 2: Produce copies of all documents, items and materials,
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`(
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`including electronically generated and stored, that show the name, type or description of products
`
` ((
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` .<+
` .
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. #∗
`Defendant contends he was working on to combat MRSA for several years before December 21,
`#∃∃%
`((
` ((
` (
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`
`Defendant contends he was working on to combat MRSA for several years before December 21,
`#∃∃%
`((
` ((
` (
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(
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`2007, and show who Defendant was working with on these products, what each person did, and
`date and location where the work was done.
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` ( (
`(
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`RESPONSE:
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` 4 +
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` .
`INTERROGATORY NO. 6: State the date and location of, and identify by name, address and
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`
`(
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(
(
`telephone number of any person present or who participated with Defendant, when Defendant
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`telephone number of any person present or who participated with Defendant, when Defendant
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(
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`
`.
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`(
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` (
`contends he came up with the idea for antimicrobial coatings to treat the growth of mold, mildew,
`.
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` ( (
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` .
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`bacteria and fungus on Various surfaces. Also state what was said or done by each person that you
`identified.
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`
`ANSWER:
` 29
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.
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`RE§ QUEST FOR PRODUCTION NO. 3: Produce copies of all documents, items and materials,
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` .
`including electronically generated and stored, that state the date and location of, and identify by
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` .
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`(
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(
`name, address and telephone number of any person present or who participated with Defendant
`(
`name, address and telephone number of any person present or who participated with Defendant
`(
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(
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`
`.
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`(
`when Defendant contends he came up with the idea for antimicrobial coatings to treat the growth
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` (.
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`(( (
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` .
`of mold, mildew, bacteria and fungus on Various surfaces, and show what was said or done by each
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`person that you identified.
`
`RESPONSE:
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` ! + .
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`INTERROGATORY NO. 7: State by name, type and description of each product that you
`
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`( (
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` .<+
` .
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. #∗#∃∃%
`contend you were working on to combat MRSA for several years before December 21, 2007, and
` .
` .
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`contend you were working on to combat MRSA for several years before December 21, 2007, and
` .
` .
`
` (
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(
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`identify by name, address and telephone number of each person who participated with you, and
`(
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`what the person did.
`
`ANSWER:
` 29
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`
`
`identify by name, address and telephone number of each person who participated with you, and
`(
`
`what the person did.
`
`ANSWER:
` 29
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3
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`
`RE; QUEST FOR PRODUCTION NO. 4: Produce copies of all documents, items, materials,
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`including electronically generated or stored, that state the name, type and description of each
`
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`
`( (
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` .<+
` .
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`product that you contend you were working on to combat MRSA for several years before
`
. #∗#∃∃%
` .
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` .
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` (
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`December 21, 2007, and the name, address and telephone number of each person who participated
`(
` (
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`with you, and what the person did.
`
`RESPONSE:
`
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` # 0
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`<+ ϑ Β
`INTERROGATORY NO. 8: For the trademark applications you had filed for MRSA, Klenzall
` Κ2
` ∋ Ι
`( .
` .
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`and VRE, D-Col and Handi Glow, identify by name, address and telephone number of each person
`(
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(
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` (
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`who participated with you, or you had communication with that relates to selecting or originating
` <+ ϑ ΒΚ2
` ∋ Ι
`(
`
`
`the names MRSA, Klenzall, VRE, D-Col and Handi Glow for trademark, and filing for the
`
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`
0
`
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` ( (
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`trademark applications for each. For each person that you identified, state what was said and done.
`
`ANSWER:
` 29
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∗
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`
`
`RE; QUEST FOR PRODUCTION NO. 5: Produce copies of all documents, materials and items,
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`(
` .
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`including electronically generated or stored, that show the name, address and telephone number of
`
` (
`
(
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` (
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`each person who participated with you, or you had communications with that relate to selecting or
`
` <+ Κ2
`∋ Ι
`( ϑ Β
`
`
`originating the names MRSA, VRE, D-Col, Handi Glow and Klenzall for trademark, and filing for
`
`
`
`(( (
`
` .
`
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`the trademark applications for each, and show what was said or done by each person that you
`identified.
`
`
`RESPONSE:
`
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` 5 +
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`.
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`
`
`INTERROGATORY NO. 9: State each fact, reason or belief that supports your contention that
`
`
`+
`(
` ∋ Ι
`(
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`you and or SRT. Inc., owned the name D-Col and Handi Glow, and had the right to register the
`domain name www.d-col.com.
`
` (((
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`
`
`ANSWER:
` 29
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4
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`RE§ QUEST FOR PRODUCTION NO. 6: Produce copies of all documents, materials and items,
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`
`+
`including electronically generated or stored, that supports your contention that you and or SRT.
`
`(
` ∋ Ι
`(
`
`
`Inc., owned the name D-Col and Handi Glow, and had the right to register the domain name
`www.d-col.com.
`(((
`
`
`
`RESPONSE:
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` ∃ +
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`
`INTERROGATORY NO. 10: State any and all association, involvement or participation that
`+
(
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` .
`SRT. Inc. had with the origination, development or formulation of any product used to combat
`<+ .
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`.
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`
`(
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` (
`MRSA, bacteria and infection, and antimicrobial coatings to treat the growth of mold, mildew,
`.
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.
`
`(
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`bacteria and fungus on various surfaces, and the business and or ownership of the names D-Col,
`(((
`
`(
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`bacteria and fungus on various surfaces, and the business and or ownership of the names D-Col,
`(((
`
` ∋ Ι
`(
`www.d-col.com, and Handi Glow.
`
`ANSWER:
` 29
`
`
!
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`
`
`RE§ QUEST FOR PRODUCTION NO. 7: Produce copies of all documents, materials and items,
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`
`(
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`
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`including electronically generated or stored, that show any and all association, involvement or
`
` +
(
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`participation that SRT. Inc. had with the origination, development or formulation of products used
`
`
` .<+ .
`
`.
`
`
`(
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`to combat MRSA, bacteria and infection, and antimicrobial coatings to treat the growth of mold,
` (.
`
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.
`
`(
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`mildew, bacteria and fungus on various surfaces, and the business and or ownership of the names
`
`(((
`
`(
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`mildew, bacteria and fungus on various surfaces, and the business and or ownership of the names
`
`(((
`
` ∋ Ι
`(
`D-Col, wvvw.d-col.com, and Handi Glow.
`
`RESPONSE:
`
`
` ∃∃ +
.
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3
4
`INTERROGATORY NO. 11: State the date Advanced Rehabilitation Technology Inc. (ART, Inc.)
`(
`INTERROGATORY NO. 11: State the date Advanced Rehabilitation Technology Inc. (ART, Inc.)
`(
`
`
`.
` (
.
`was incorporated, the type of business ART, Inc. engaged in, reason it was created, identify by
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` .
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`was incorporated, the type of business ART, Inc. engaged in, reason it was created, identify by
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`name, address and telephone number of each stockholder, number of shares or percentage of ART,
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`( .
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`Inc. each person owned, identify by name, type, description and purpose of all products created,
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`.
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`manufactured or sold by or through ART, Inc., state if ART, Inc. is still active, and if not, state the
` .
`(
` ( .
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