LSI objects to FHE’s Instruction No. 3 as seeking to impose burdens or obligations beyond what is permitted by the Federal Rules of Civil Procedure, as it purports to require a “diligent inquiry” to provide “as specific and responsive as possible.” Fed. R. Civ.
LSI objects to FHE’s Instruction No. 4 as vague, ambiguous, and seeking to impose burdens or obligations beyond what is permitted by the Federal Rules of Civil Procedure to the extent it contends that the “fact that investigation is continuing or that discovery is not complete shall not be used as an excuse.” LSI objects to FHE’s Instruction No. 4 as vague, ambiguous, and seeking to impose burdens or obligations beyond what is permitted by the Federal Rules of Civil Procedure to the extent it contends that the “omission of any name, fact, or other item of information from the answers shall be deemed a representation that such name, fact, or item is not known.” LSI objects to FHE’s Instruction No. 4 to the extent that it seeks information protected by the attorney-client privilege, work- product privileges, or other applicable protections and privileges, beyond what is permitted by the Federal Rules of Civil Procedure, which authorizes discovery of only “nonprivileged matter[s]” under Federal Rule of Civil Procedure 26(b)(1).
LSI objects to FHE’s Instruction No. 7 as seeking to impose burdens or obligations beyond what is permitted by the Federal Rules of Civil Procedure, as it purports to require a “diligent inquiry” to provide “provide as complete an answer as possible.” LSI objects to FHE’s Instruction No. 7 as overbroad, unduly burdensome, and seeking to impose burdens or obligations beyond what is permitted by the Federal Rules of Civil Procedure, since Fed. R. Civ.
LSI objects to this Interrogatory as overbroad, unduly burdensome, and disproportionate to the needs of the case as it seeks identification of each “each person having knowledge about or involvement in” the activities relating to the Accused Product.
I have reviewed the foregoing Defendant Lee Specialties Inc.’s Objections and Responses to Plaintiff FARE USA LLC'S First Set of Interrogatories (Nos. 1-7) and am familiar with its contents.