Document V3NKkRdmLey3q0D17penjbw2p

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION WILLIAM R. GAFFEY, Plaintiff, vs. PETER MONTAGUE, et al., Defendants. ) ) ) ) ) Cause No. 91-1938-C-7 JCH ) ) ) ) DEFENDANTS' RESPONSE TO PLAINTIFF1S REQUEST FOR PRODUCTION OF DOCUMENTS Come now defendants, and for their response to plaintiff's request for production of documents, state as follows: GENERAL INSTRUCTIONS AND DEFINITIONS Defendants object to plaintiffs' general instructions and definitions as being overbroad, burdensome, vague, and beyond the scope of discovery. 1. OBJECTION: This is overbroad, burdensome, not reasonably calculated to lead to the discovery of admissible evidence, and could include materials protected by work product, trial preparation, and attorney-client privilege. Subject to and without waiving these objections, see attached list. 2. OBJECTION: See objection to number 1, and this general information is equally available to plaintiff. 3. OBJECTION: See objection to number 1. In addition, this seeks documents which would constitute and invasion of privacy of third parties. Subject to and without waiving these objections, see answer to interrogatory number 2, and document number 00001. 4. OBJECTION: See objection to number 1. Also, the term r "standards" is vague and calls for conclusions. 5. OBJECTION; See objection to number 1. Subject to and without waiving the objections, defendants produce correspondence, which are numbered 000196 - 000415. 6. OBJECTION: See objection to number 1. Subject to and without waiving the objections, documents are produced, numbered 00002 - 00007. 7. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants produce published work relating to dioxin, which are numbered 00008 - 000159. 8. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants have no such documents. 9. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants have no written review of the article prior to publication. 10. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants have no interviews or field notes. 11. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants produce documents numbered 000160 - 000191. 12. OBJECTION: See objection to number 1 and the request is vague. Subject to and without waiving the objections, defendants produce documents numbered 000160 - 000191; 000192 000195. 13. OBJECTION: See objection to number 1. Subject to and without waiving the objections, see response to number 12. 14. OBJECTION: See objection to number 1. Subject to and without waiving the objections, none other than in the present action. 15. OBJECTION: See objection to number 1. Also, this request would constitute and invasion of privacy of third parties. Subject to and without waiving any objections, see documents numbered 000416 - 000555. 16. OBJECTION: See objection to number 1. Subject to and without waiving the objections, defendants produce documents numbered 000196 - 000415. 17. OBJECTION: See objection to number 1, and defendants incorporate all objections made in responses to interrogatories. 18. OBJECTION: See objection to number 1. 19. OBJECTION: See objection to number 1. In addition, this isan improper method of obtaining discovery from an expert witness. EVANS & DIXON John A. Michener #22509 Kathi L. Chestnut #33358 Co-Counsel for Defendants 1200 Saint Louis Place 200 North Broadway St. Louis, MO 63102 621-7755 CERTIFICATE OF SERVICE Copy of the foregoing mailed this ^6 day of November, 1993 to Richard A. Wunderlich, Daniel D. Zegura, Attorneys for Plaintiff, 8182 Maryland Avenue, Suite 400, Clayton, MO 63105; and Gerald R. Ortbals, Attorney for Defendants, 1800 Equitable Building, 10 South Broadway, St. Louis, MO 63102.