Document VJo58ERjxq6gj3M7erQjjqe6o

NO. CC-00-06741-B RAYMOND EMERY DAILEY, SR. and PRISCILLA DAILEY, Individually and as Next Friends of RAYMOND EMERY DAILEY, JR., a Minor Plaintiffs, IN THE COUNTY COURT AT LAW #2 vs. GAF CORPORATION (successor to RUBERROID CORPORATION); et al. Defendants. DALLAS COUNTY TEXAS OBJECTIONS AND RESPONSES TO PLAINTIFF'S REQUESTS FOR PRODUCTION AND REQUESTS FOR ADMISSION PROPOUNDED TO DEFENDANTS BROWN & ROOT HOLDINGS. INC.. AND BROWN & ROOT. INC. TO: Plaintiff, by and through its attorney of record, Ben K. DuBose, Baron & Budd, P.C. 3102 Oak Lawn Ave., Suite 1100, Dallas TX 75219-4281 COMES NOW, Brown & Root, Inc.,n/k/a Kellogg Brown & Root, Inc., Defendant in the above-entitled and numbered cause, and serves these its Objections and Responses to Plaintiffs Request for Admission, and Requests for Production, pursuant to Rules 194, 196 and 197 of the Texas Rules of Civil Procedure. u; DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS PAGE 1 J Respectfully submitted. GODWIN WHITE & GRUBER, P.C. BY: Dallas, Texas 75202-3727 (214) 939-4400 (office) (214) 760-7332 (telecopier) ATTORNEYS FOR DEFENDANT BROWN & ROOT, INC. CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been served via First Class United States Mail to Plaintiffs counsel, Baron & Budd 3102 Oak Lawn Ave., Suite 1100 Dallas TX 75219-4281 on this the day of April, 2001. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS PAGE 2 PRELIMINARY STATEMENT APPLICABLE TO ALL REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION Subject to the limitations set' forth in this Preliminary Statement and Common Objections set forth below, Defendant responds to the Plaintiff's Requests for Admission and Requests for Production. It should be noted that the events at issue in this case are alleged to have occurred many years ago, and continuing investigation, further discovery, independent investigation, legal research, and analysis may supply additional facts and add meaning to known facts, as well as establish entirely new factual conclusions and legal contentions, all of which may lead to substantial changes to, changes in, and variations from the responses set forth herein, which are based on the results of investigation to date. Responses provided previously, and prior to subsequent investigation, should be considered supplemented and/or amended by the responses herein. It should be further noted that the entity sued is Kellogg Brown u Root, Inc., for alleged acts or omissions of a predecessor entity, Brown i Root, Inc. Responses are provided only as to Brown & Root, Inc., and not as to any other predecessor entity. The documents identified which Defendant agrees to provide for inspection in response to these specific requests for productions will be provided for inspection and copying upon reasonable notice at the office of Defendant's counsel. COMMON OBJECTIONS TO REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION Each and every discovery request herein is responded to subject to the common objections set forth below. These objections are set forth here to avoid the duplication and repetition of restating them in each response. These common objections may be specifically referred to herein for the purposes of clarity. Defendant's failure to specifically incorporate a common objection in a response, however, should not be construed as a waiver of the common obj ection. 1. Defendant objects to each request for information and documents to the extent it seeks information or documents protected from disclosure by the attorney-client privilege and/or the attorney work product privilege provided for by Tex. R. Civ. ?. 1S2 and Tex. R. Evid. 503. 2. Defendant further objects to each request for information, or documents to the extent chat it seeks non-relevant information or documents. As used herein, all objections as to relevance shall mean that information or documents requested are irrelevant to the subject matter involved in the pending action and are not reasonably calculated to lead to the discovery of admissible evidence. 3. Defendant further objects to each request for information or documents to the extent that it seeks information or documents equally accessible to Plaintiff as to Defendant. 4. Defendant further objects to each request for information or documents to the extent it seeks information or documents not in the possession or control of Defendant. 5. Defendant further objects in that the interrogatories require answers in excess of the maximum allowable number of such requests in violation of the rule of limitation of interrogatories. Tex. R. Civ. P. 190.3. 6. Defendant further objects to the use of the term "asbestos products," as well as any variation of this term, on the grounds that its use mischaracterizes the nature and scope of Defendant's business. 7. Defendant further objects to each request for information and documents to the extent it seeks information and documents "in anyway related to," on the grounds that the use of this term renders such request overly broad and vague. . s usf:t::::s ,, ffsisnse; t: fiaintiffs- request foe admissions and request fc?. COMMON OBJECTIONS APPLICABLE TO THE "DEFINITIONS" SECTION IN PLAINTIFF'S REQUESTS FOR ADMISSION AND FIRST REQUEST FOR PRODUCTION Defendant objects to the "DEFINITIONS" section in Plaintiff's Requests for Admissions and Request for Production of Documents and each and every "definition" contained in the "DEFINITIONS" section on the grounds that this section and the "definitions" contained therein purport to create and/or impose obligations upon Defendant beyond those contained in the Texas Rules of Civil Procedure. Defendant further objects to the following definitions: 1. Defendant objects to the definitions of "You", "Your company", "Defendant" and "Person(s)", on the grounds that these definitions are vague and ambiguous, overly broad, harassing and burdensome. Defendant further objects to these definitions as calling for discovery from an entity other than the named Defendant in this case. Finally, Defendant objects to these definitions as calling for documents protected from discovery by the attorney-client privilege, attorney work product privilege, and/or joint defense privilege. 2. Defendant objects to the definition of "Document(s)", "written materials" and "Printed matter" as calling for tefeneant s objections i responses tc plaintiffs' request for admissions and request for documents protected by the attorney-client privilege, the attorney work product privilege, the joint defense privilege and also seeks to discover matters exempt from discovery and/or privilege as trade secrets and/or proprietary and/or confidential information. Defendant further objects to the definition of "Document (s) " , ''written materials" and "Printed matter" as vague, ambiguous, overly broad, unduly burdensome and harassing. Finally, Defendant objects to the definition of "Document(s)", "written materials" and "Printed matter" as calling for documents that are as readily available to Plaintiff as to Defendant. Subject to the foregoing common objections, Defendant makes and serves these its Objections and Answers to Plaintiff's Requests for Admissions and Requests for Production as follows: Request for Admission No. 1: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #1 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. :ns i RES POMS )ANTS - PAGE LAINTI FFS ' REQUEST FOR ADMISSIONS AND REQUEST FOR Request for Production No. 1: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 2: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #2 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant; objections i responses to plaintiffs' request fcp. adIMISSICtJS AND REQUEST for Request for Production No. 2: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 3: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #3 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's isjedtions i responses tc ?da::;?:ffs' request foe admissions ajjd request for Request for Production No. 3: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 4: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #4 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's osjeoticns i responses to plaintiffs' request fop. admissions and request for PRODUCT I Zil TC DEFENDANTS - PAGE 13 Request for Production No. 4: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 5: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #5 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. 3 z. F-NDANT ' S OBJECTION'S i RESPONSES TO r' LAI NT I F F3 REO'JEST FOP. ADM I SS I DNS AND REC'USST FOR PRODUCT ION TO DEFENDANTS - PAGE 11 Request for Production No. 5: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 6: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #6 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOP, ADMISSIONS AND REQUEST FOR PRODUCT:ON TO DEFENDANTS - PAGE 12 Request for Production No. 6: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 7: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #7 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to plaintiffs- request for admissions and request FOR PRODUCTION TO DEFENDANTS - PAGE 13 Request for Production No. 7: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 8: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #8 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS A RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 14 Request for Production No. 8: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 9: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #9 is a true and correct copy of the original. RESPONSEDenied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS S, RESPONSES 70 PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 15 Request for Production No. 9: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 10: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #10 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. _or EN'DAN. S S3Jr.E.I0NS u RESPONSES TC PLAINTIFFS REQUEST PF.DDUCTIDN TC DEFENDANTS - PAGE IS ISSIONS AND REQUEST FOR Request for Production No. 10: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 11: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #11 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMI3 SIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 17 Request for Production No. 11: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is ' overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 12: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #12 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. liriMA-'.T'S CSUECTICD'S i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCT I ON TO DEFENDANTS - PAGE 16 Request for Production No. 12: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 13: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #13 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. 1n)DA!' D CEDED* ION'S i EESrONSES TO fDAIN:IFF'S' REQUEST EOR ADMISSIONS AND REQUEST FOR Request for Production No. 13: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 14: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #14 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEr ENDAN. ' 3 OBJECTIONS i RESPONSES ? RCC'JCT I ON TO DEPENDANTS - PAGE 20 REQUEST R ADMISSIONS AND REQUEST FOR Request for Production No. 14: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 15: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #15 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 1 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 21 Request for Production No. 15: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 16: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #16 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. S r z.1' LAN. ' 3 IBUECTICN3 3 RESPONSES TO PLAINTIFFS' R.EQUEST FOP. ADMISSIO>NS AND REQUEST FOR Request for Production No. 16: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is ' overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 17: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #17 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 23 Request for Production No. 17: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 18: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #18 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 24 Request for Production No. 18: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 19: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #19 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 25 Request for Production No. 19: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 20: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #20 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 26 Request for Production No. 20: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 21: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #21 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 2? Request for Production No. 21: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 22: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #22 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTION'S 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 28 Request for Production No. 22: If you denied the preceding request for Admission, either in whole or in part, then produce any ana all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 23: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #23 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to plaintiffs1 request for admissions and request for ?E DELICTI ON TO DEFENDANTS - PAGE 2 9 Request for Production No. 23: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents rc be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 24: Admit that the or. Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #24 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. :Er:)DA.':T,3 OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 30 Request for Production No. 24: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 25: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #25 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 31 Request for Production No. 25: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 26: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #26 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. s dejections i responses to plaintiffs' request for admissions and request for production to defendants - page 32 Request for Production No. 26: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 27: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #27 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 33 Request for Production No. 27: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 28: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #28 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 34 Request for Production No. 28: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 29: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #2S correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant-s objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 35 Request for Production No. 29: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 30: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #30 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. "PENDANT' ? OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR Request for Production No. 30: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 31: Admit that the on Plaintiffs' Exhibit List (attached hereto .incorporated herein by reference) as B&R #31 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRCOUST I ON TO DEFENDANTS - PAGE 37 Request for Production No. 31: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 32: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #32 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'3 OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 38 Request for Production No. 32: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 33: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #33 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant s objections u responses to plaintiffs' request for admissions and request for p p. b b J bT I bb TO DEFENDANTS - PAGE 39 Request for Production No. 33: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 34: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #34 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it. is a true and correct copy of the original, and this request is deemed denied. IONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR NTANTS - PAGE 40 Request for Production No. 34: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents'' is vague, overbroad and undefined. Request for Admission No. 35: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #35 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS ANO REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 41 Request for Production No. 35: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 36: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #36 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's rejections & responses to plaintiffs' request for admissions ^nd request for PRODUCTION TC DEFENDANTS - PAGE 42 Request for Production No. 36: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 37: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #37 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 4 3 Request for Production No. 37: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible ac trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 38: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #38 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 44 Request for Production No. 38: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 39: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #3S correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S DEJECTION'S i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 45 Request for Production No. 39: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 40: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #40 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 46 Request for Production No. 40: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 41: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #41 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 47 Request for Production No. 41: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 42: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #42 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's dbuedtidns & responses to plaintiffs' request for admissions and request for pf.cevcticn to defendants - page -is Request for Production No. 42: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 43: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #43 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant-s objection's & responses tc plaintiffs' request for aEMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 4 9 Request for Production No. 43: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 44: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #44 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'3 OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 50 Request for Production No. 44: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in yqur custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity che documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 45: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #45 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 51 Request for Production No. 45: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is ' overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 46: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #46 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's OBJECTIONS i RESPONSES TC FLAINTIFFS' request for admissions and request for product:;:; to defendants - page 52 Request for Production No. 46: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 47: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #47 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 47: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 53 Request for Admission No. 48: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #48 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 48: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 49: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #49 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 49: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. RESPONSES TO PLAIN'T IFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR Request for Admission No. 50: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #50 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 50: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 51: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #51 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 51: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. objections i responses tc plaintiffs' request for admissions and request for ppzzzztzz:: 70 DEFENDANTS - PAGE 55 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 52: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #52 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 52: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 53: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #53 correct copy of the original. document identified as Exhibit "A" and is a true and DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR ?f:dcdt:dn to defendants - page 56 RESPONSE: Admitted. Request for Production No. 53: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 54: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #54 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 54: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents DEFENDANT'S OBJECTIONS 5, RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSION'S AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 57 to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 55: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #55 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 55: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 56: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #56 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. tefentant'S oejetticns i responses to plaintiffs' reguest for adkissicns ant request for FRTTTTTIC:; TO TEFENDANTS - PAGE 58 Request for Production No. 56: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 57: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #57 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 57: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 59 this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 58: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #58 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 58: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 60 at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 59: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #59 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 59: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 60: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #6C is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 60: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 51 custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 61: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #61 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 61: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 62: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #62 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Admitted. Request for Production No. 62: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. defendants :ssections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 62 Request for Admission No. 63: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #63 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 63: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 64: Admit that the on Plaintiffs' Exhibit List (attached hereto incorporated herein by reference) as B&R #64 correct copy of the original. document identified as Exhibit "A" and is a true and RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 64: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS- AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE S3 Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 65: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #65 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 65: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, ocssession or control. DEFEND^;':'S OBJECTIONS * RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 64 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No, 66: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #66 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 66: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 67: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and defendant's detections u RE3FCNSES TO PLAINTIFFS' request for admissions and request for PFI.TUITi::.- TO DEFENDANTS - PAGE 65 incorporated herein by reference) as B&R #67 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 67: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 68: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #68 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 68: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 69: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #69 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and OSFF.'.'OANT 'S OBJECTIONS & RESPONSES TC PLAINTIFFS' REQUEST FOR ADMI SSICNS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 66 information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 69: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents tc be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 70: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #70 is a true and correct copy of the original. OEFENDANT' 5 OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 67 RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 70: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 71: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #71 is a true and defendant's objections u responses to plaintiffs' request for admissions and request for PRDD-GTION TO DEFENDANTS - PAGE 68 correct copy of the original. RESPONSE: Admitted. Request for Production No. 71: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 72: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #72 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 72: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that iefendant1s objection's s responses to plaintiffs' request for admissions and request for prijujt:::: tc defendants - page 69 it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 73: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #73 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 73: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that DEFENDANT'3 OBJECTIONS & RESPONSES TC PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 70 it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 74: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #74 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 74: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 71 it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. P.ecuest for Admission No. 75: Admit that the document identified cn Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #75 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 75: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. cejestic.ns i responses to plaintiffs' request for admissions and request for pfodudticn to defendants - page 72 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 76: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #76 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 76: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. defendant s objections & responses to plaintiffs' request for admissions and request for FF.IDTDTIDN TC DEFENDANTS - PAGE 73 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 77: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #77 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 77: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 74 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 78: Admit that the document identified on Plaintiffs' Exhibit List {attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #78 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 78: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 75 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 79: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #79 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 79: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. defendant's orjecticns & responses to plaintiffs' request for admissions and request for PRCSUCTION TO DEFENDANTS - PAGE 76 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 80: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #80 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 80: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for :z?endant's objections & responses to plaintiffs' request for admissions and request for PECCUCTION TO DEFENDANTS - PAGE 77 Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 81: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #81 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No, 81: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. DEFENDANT' S OBJECTIONS S, RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 78 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 82: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #82 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 82: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 79 custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 83: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #83 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 83: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' request fop. admissions and request for PRODUCTION TO DEFENDANTS - PAGE 80 custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 84: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #84 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 84: If you denied the preceding defendant* S OBJECTIONS i RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 81 request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 85: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #85 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S DEJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 82 Request for Production No. 85: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 86: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #86 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE S3 Request for Production No. 86: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 87: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #87 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to plaintiffs' request fop. admissions and request for PRODUCTION TO DEFENDANTS - PAGE 84 Request for Production No. 87: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 88: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #88 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 8S Request for Production No. 88: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 89: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #89 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 36 Request for Production No. 89: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 90: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #90 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 87 Request for Production No. 90: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 91: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #91 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'5 OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 88 Request: for Production No. 91: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 92: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #92 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION' TO DEFENDANTS - PAGE 89 Request for Production No. 92: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 93: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #93 is a true and correct copy of the original. RESPONSE.- Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 90 Request for Production No. 93: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 94: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #94 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 91 Request for Production No. 94: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 95: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #95 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 92 Request for Production No. 95: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 96: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #96 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 93 Request for Production No. 96: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 97: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #97 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 94 Request for Production No. 97: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 98: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #98 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 95 Request for Production No. 98: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 99: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #99 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TC DEFENDANTS - PAGE 96 Request for Production No. 99: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 100: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #100 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and ** correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 97 I Request for Production No. 100: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 101: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #101 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 98 Request for Production No. 101: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 102: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #102 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 99 Request for Production No. 102: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 103: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #103 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 100 Request for Production No. 103: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents tc be produced, as well as on the grounds that it is . . overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 104: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #104 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. D . ' 5 OBJwC.ICNS & RESPONSES TC PLAINTIFFS' REQUES* r OP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 101 Request for Production No. 104: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad ar.d undefined. Request for Admission No. 105: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #105 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. objections s. responses to plaintiffs1 request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 102 Request for Production No. 105: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 106: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #106 is a true'and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections i responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 103 Request for Production No. 106: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 107: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #107 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's isjecticns & responses to plaintiffs' request for admission's and request for PRODUCTION TO DEFENDANTS - PAGE 104 Request for Production No. 107: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 108: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #108 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTION'S & RESPONSES TO PLAINTIFFS' request for admissions and request for PRCCUCTION TO DEFENDANTS - PAGE 105 Request for Production No. 108: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 109: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #109 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT S OBJECTIONS > RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 106 Request for Production No. 109: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 110: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #110 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S DEJECTIONS 4 RESPONSES TC PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 107 Request for Production No. 110: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. Ill: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #111 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 108 Request for Production No. Ill: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 112: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #112 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. EEFSNDANT' s DEJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 109 Request for Production No. 112: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 113: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #113 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is tefenoant' = eejeetions i responses to plaintiffs' request for admissions and request for rr T . Z e. DANTS * PAGE 110 deemed denied. Request for Production No. 113: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 114: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #114 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE ill document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 114: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 115: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #115 is a true and correct copy of the original. defendant' s objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 112 RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 115: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents co be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 116: Admit that the document identified defendant1s objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 113 on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #116 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No, 116: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. defendant'; dsjedtidns i responses to plaintiffs' request fop. admissions and request for production to defendants - page up Request for Admission No. 117: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #117 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 117: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. objections & responses to plaintiffs' request for admissions and request for PRC DUCT I ON TO DEFENDANTS - PAGE US Request for Admission No. 118: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #118 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 118: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. defendant' s objections u responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 116 Request for Admission No. 119: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #119 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 119: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence chat will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT' 5 OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 111 Request for Admission No. 120: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #120 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 120: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad defendant's iejedtidns i responses to plaintiffs' request for admissions and request for production to defendants - page ns and undefined. Request for Admission No. 121: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #121 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 121: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to DEFENDANT' 3 OBJECTION'S 5. RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR pp.ccjct:::: to defendants - page ns this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 122: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #122 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 122: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. (Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably DEFENDANT'S OBJECTIONS 1 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 120 calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 123: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #123 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 123; If you denied the preceding request for Admission, either in whole or in part, then produce any.and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is RESPONSES 70 PAGc. lii q ' REQUEST FOR ADMISSIONS AND REQUEST FOR overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 124: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #124 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 124: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents ZZZZZ'.IS i RESPONSES TO PLAINT IrrS' REQUEST FOR ADMISSIONS AND REQUEST FOR to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 125: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #125 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 125: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT' s OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for product:;:: to defendants - page :23 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 126: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #126 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 126: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 124 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents co be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 127: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #127 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 127: If you denied the preceding DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 125 request for.Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents'' is vague, overbroad and undefined. Request for Admission No. 128: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #128 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. c :CNSES 70 PLAINTIFFS REQUEST FOR ADMISSIONS AND REQUEST FOR Request for Production No. 128: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 129: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #129 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR r PCC'J 27 I 3C TO DEFENDANTS PAGE 12 / Request for Production No. 129: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 130: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #130 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DDFENDANTS - PAGE 128 Request for Production No. 130: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 131: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #131 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is DEr ENDANT' 3 03JEETICNS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUES' product:::; to defendants - page 129 `OR deemed denied. Request for Production No. 131: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 132: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #132 is a true and correct copy of the original. RESPONSE Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and objections i responses to plaintiffs- request for admissions and p.equest for correct copy of the original, and this request is deemed denied. Request for Production No. 132: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 133: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #133 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOP. PRODUCTION TC DEFENDANTS - PAGE 131 information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 133: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 134: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #134 is a true and DEFENDANT'S OBJECTIONS U RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRCEUCTICN TO DEFENDANTS - PAGE 132 correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 134: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS 6, RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 133 Request for Admission No. 135: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #135 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 135: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. sdefendant' tidns d responses tc plaintiffs' PRCDVDTION TO DEFENDANTS - PAGE 134 request for admissions and request for Request for Admission No. 136: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #136 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 136: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS 5, RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 135 Request for Admission No. 137: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #137 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 137: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCT ION TO DEFENDANTS - PAGE 136 ana undefined. Request for Admission No. 138: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #138 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 138: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 137 this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 139: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #139 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 139: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 136 calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 140: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #140 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 140: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is s fejeoticns & responses to plaintiffs 1 productto defendants - page 139 request for admissions and request for overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 141: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #141 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 141: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE HO co be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 142: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #142 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 142: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTION'S & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 141 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 143: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #143 is a true and correct copy of the original.See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 143: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your DS F ENDANT' 3 DETECTIONS u RESPONSES TO PLAINT I EPS' P. E GOES T FOR ADMISSIONS AND REQUEST FOR PEGDTSTICN TC DEFENDANTS - PAGE 142 custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 144: Admit that the document identified cn Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #144 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' 5 OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE H3 Request for Production No. 144: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents tc be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 145: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #145 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE l-l-l Request for Production No. 145: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 146: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #146 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 145 Request for Production No. 146: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 147: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #147 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is DEFENDANT'S OBJECTION'S & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 146 deemed denied. Request for Production No. 147: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 148: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #148 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 147 document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 148: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSESee Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 149: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #149 is a true and correct copy of the original. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 148 RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 149: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 150: Admit that the document identified DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 1*3 9 on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #150 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 150: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. sdefendant' objections & responses to plaint: FFS' REQUEST FOR ADMISSION'S AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 150 Request for Admission No. 151: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #151 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 151: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSESee Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S 03JECTICNS 4 RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 151 Request for Admission No. 152: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #152 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 152: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents tc be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents'' is vague, overbroad and undefined. DEFENDANT'S DEJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR FF.CC'JCTION TO DEFENDANTS - PAGE 152 Request for Admission No. 153: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #153 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 153: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 153 Request for Admission No. 154: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #154 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No, 154: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 154 Request for Admission No. 155: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #155 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No, 155: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad DEFENDANT' 3 OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 155 and undefined. Request for Admission No. 156: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #156 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 156: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to defendant-s objections i responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 156 this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 157: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #157 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 157: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 157 calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 158: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #158 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 158: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is objections e. responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 158 overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 159: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #159 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 159: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIF FS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 159 overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 160: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #160 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 160: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 160 to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 161: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #161 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 161: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTIONS A RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCT ICN TO DEFENDANTS - PAGE 161 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 162: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #162 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 162: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 162 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 163: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #163 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 163: If you denied the preceding DEFENDANT'S OBJECTIONS &. RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 163 request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 164: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #164 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S DEJECTION'S & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 164 Request for Production No. 164: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 165: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #165 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PF.CDUCTION TC DEFENDANTS - PAGE 165 Request for Production No. 165: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents ;c be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 166: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #166 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 166 deemed denied. Request for Production No. 166: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 167: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #167 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 167 document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 167: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence chat will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 168: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #168 is a true and correct copy of the original. dejections u responses to plaintiffs' recuest for .admission's and seguest for PRODUCTION TO DEFENDANTS - PAGE 168 RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 168: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 169: Admit that the document identified defendant's objections & responses to plaintiffs' request for admissions and request for PRODUCTION TC DEFENDANTS - PAGE 1S9 on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #169 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 169: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. defendant's objections & responses to plaintiffs' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 173 Request for Admission No. 170: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #170 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 170: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 171 Request for Admission No. 171: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #171 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 171: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTION'S & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 172 Request for Admission No. 172: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #172 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 172: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 173 and undefined. Request for Admission No. 173: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #173 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 173: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for rROEVCTION TO DEFENDANTS - PAGE 174 this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 174: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #174 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 174: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably DEFENDANT'S OBJECTIONS S, RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 17S calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 175: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #175 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 175: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably " 3 3 E J E3TIONS 1 RESPONSES TO PDAINTI r FS ' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 176 calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 176: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #176 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 176: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is izfzndant's objections i RESPONSES TO PLAINTIFFS' request for admissions and request for overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 177: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #177 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 177: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents defendant-- dsjedticns i responses to plaintiffs' reclest for admissions and request for priduot:;:: to defendants - page ho to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 178: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #178 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 178: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTIONS u RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCT:ON TO DEFENDANTS - PAGE 179 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 179: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #179 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 179: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS * PAGE 180 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 180: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #180 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 180: If you denied the preceding defendant s objections & responses to plaintiffs' request for askissions and request for PECD'JTTICN TO DEFENDANTS - PAGE 191 request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 181: Admit that: the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #181 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's qbjedticns i responses to plaintiffs' request fop. admissions PRODUCTION' TO DEFENDANTS - PAGE 182 DID REQUEST FOR Request for Production No. 181: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 182: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #182 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. DEFENDANT' S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 183 Request for Production No. 182: If you denied the preceding request for Admission, either in whole or in part, then produce ar.y and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 183: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #183 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' request for admissions and request for PRODUCTION TO DEFENDANTS - PAGE 184 deemed denied. Request for Production No. 183: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. l Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 184: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #184 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 185 document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 184: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 185: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #185 is a true and correct copy of the original. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 13S RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 185: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 186: Admit that the document identified DEFENDANT'S OBJECTIONS 4 RESPONSES 00 PLAINTIFFS ' REQUEST FOR ADMISSION'S AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE I3T on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #186 is a true and correct copy of the original. RESPONSEDenied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 186: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents tc be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. defendant's OBJECTIONS i RESPONSES to plaintiffs ' REQUEST fop ad,fissions and recusst for PEDDCCTION TO DEFENDANTS - PAGE 13 = Request for Admission No. 187: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #187 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 187: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. defendant's objections & responses to plaintiffs' request fop. admissions and request for fpcouctic:: TO DEFENDANTS - PAGE 1S9 Request for Admission No. 188: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #188 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 188: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCT ION TO DEFENDANTS - PAGE 190 Request for Admission No. 189: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #189 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 189: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad EEFENEANT' S OBJECTIONS i RESPONSES TC PLAINTIFFS' REQUEST ESP. REMISSIONS AND REE'JEST FOR PRODUCTION TO DEFENDANTS - PAGE 191 and undefined. Request for Admission No. 190: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #190 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 190: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence chat will be admissible at trial in this matter. Defendant further objects to defendant's dsjeoticns & responses to plaintiffs' eecoest foe admissions and request for this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request: for Admission No. 191: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #191 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No, 191: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it rails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably DEFENDANT'S CSUEOTIONS & RESPONSES TO PLAINTIFFS' request foe admissions and REQUEST FOR calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 192: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #192 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 192: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents RES ?ON - PAGE S TO PLAINT I FFS ' REQUEST FOR ADKI55-DM3 AND REQUEST FOR to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 193: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #193 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 193: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 195 to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad ana undefined. Request for Admission No. 194: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #194 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 194: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. ticns i responses to plaintiffs' request for admissions and request for 'END-ANTS - PAGE 196 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 195: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #195 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 195: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. DEFENDANT' S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS MID REQUEST FOR PROTECTION TO DEFENDANTS - PAGE 197 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 196: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #196 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 196: If you denied the preceding I E FEUI A'.'T ' 3 0SJE0TI3NS u RESPONSES TO PLAINTIFFS' REQUEST FOR AON IS 3 I ON S AND REQUEST FOR request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents'' is vague, overbroad and undefined. Request for Admission No. 197: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #197 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. defendant's objections & responses to PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR fedduotidn to defendants - page 195 Request for Production No. 197: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. > Request for Admission No. 198: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #198 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. :-F::;VT,S CEUEDTICNS i RESPONSES to PLAINTIFFS' request fop. admissions and request for ;t:dn t: defendants - page pod Request for Production No. 198: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 199: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #199 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is defendant's objections & responses to foaintiffs' request fop. admissions and request fop. PRODUCTION TO DEFENDANTS - PAGE 2C1 deemed denied. Request for Production No. 199: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 200: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #200 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the defendant's csjeoticns & responses to plaintiffs' request fop. admissions and request for PRODTCTIC:: TO DEFENDANTS - PAGE 2C2 document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 200: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE I See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 201: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #201 is a true and correct copy of the original. oefenoant's oejeoticns i responses to plaintiffs' request fo'R ADMISSIONS AND REQUEST FOR PECOUGT 1CN TO 0EFEN'HANTS - PAGE 203 RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 201: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 202: Admit that the document identified or. Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #202 is a true and sffflialt's ;eje~:c::s i responses to plaintiffs' request ?c?. admissions and request for correct copy of the original. RESPONSE: Admitted. Request for Production No. 202: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 203: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #203 is a true and correct copy of the original. RESPONSE: Admitted. Request for Production No. 203: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 204: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #204 is a true and correct copy of the original. defendant's objections & resfonses to plaintiffs' request fof. admissions and request for PRODUCTION TO DEFENDANTS - PAGE 205 RESPONSE: Admitted. Request: for Production No. 204: If you denied the preceding request: for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: Not applicable. Request for Admission No. 205: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #205 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 205: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents DEFENDANT' S DEJECTION'S S, RESPONSES TO PLAINTIFFS' request for admissions and request for product id:: to DEFENDANTS - PAGE 2 06 to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 206: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #206 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 206: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOE ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 207 Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 207: Admit that the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #207 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 207: If you denied the preceding request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custodv, possession or control. DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 208 RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 208: Admit thac the document identified on Plaintiffs' Exhibit List (attached hereto as Exhibit "A" and incorporated herein by reference) as B&R #208 is a true and correct copy of the original. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the document to admit or deny whether it is a true and correct copy of the original, and this request is deemed denied. Request for Production No. 208: If you denied the preceding DEFENDANT'S OBJECTIONS 4 RESPONSES TO PLAINTIFFS' REQUEST FOP. ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 209 request for Admission, either in whole or in part, then produce any and all substantially similar documents which are in your custody, possession or control. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it fails to identify with particularity the documents to be produced, as well as on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to evidence that will be admissible at trial in this matter. Defendant further objects to this request on the grounds that the phrase "all substantially similar documents" is vague, overbroad and undefined. Request for Admission No. 209: Admit that each and every document listed on the attached Exhibit "A" satisfies the authenticity requirements of TEX.R.CIV.EVID. 901. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the documents to admit or deny whether they satisfy the authenticity requirements of TEX.R.CIV.EVID. 901, and this request is deemed denied. defendant-s objections & responses to plaintiffs- request for. admissions and request for PECD'JCTICN TO DEFENDANTS - PAGE 210 Request for Production No. 209: As to any documents listed on the attached Exhibit "A", the authenticity of which you are denying in response to the foregoing Request, produce all documents which support your denial, in whole or in part. RESPONSE: See Defendant's response to Request for Admission No. 209, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects that this Request fails to identify with particularity the documents to be produced. Request for Production No. 210: As to any documents listed on the attached Exhibit "A", the authenticity of which you are denying in response to the foregoing Request, produce any and all versions of such document, the authenticity of which you are willing to admit. RESPONSE: See Defendant's response to Request for Admission No. 209, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Defendant further objects to this request on the grounds that the phrase "any and all versions of DEFENDANT' 3 OBJECTION'S & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR RRCCUCTICN TO DEFENDANTS - PAGE 211 such documents" is overbroad, vague and undefined. Request for Admission No. 210: Admit that each and every document listed on the attached Exhibit "A" satisfies at least one of the categories of authenticity provided for in TEX.R.CIV.EVID. 902. RESPONSE: Denied. Defendant lacks sufficient knowledge and information concerning the origin and identity of the documents to admit or deny whether they satisfy the authenticity requirements of TEX.R.CIV.EVID. 901, and this request is deemed denied. Request for Production No. 211: As to any documents listed on the attached Exhibit "A", the self-authenticating nature of which you are denying in response to the foregoing Request, produce all documents which support your denial, in whole or in part. RESPONSE: See Defendant's response to Request for Admission No. 210, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. DEFENDANT' C EJECTIONS u RESPONSES TO PLAINTIFFS' p.eques? for admissions and request for Request for Production No. 212: As to any documents listed on the attached Exhibit "A", the self-authenticating nature of which you are denying in response to the foregoing Request, produce any and all versions of such document, the authenticity of which you are willing to admit. RESPONSE: See Defendant's response to Request for Admission No. 210, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Defendant further objects to this request or. the grounds that the phrase "any and all versions of such documents" is overbroad, vague and undefined. Request for Admission No. 211: Admit that each and every document listed on the attached Exhibit "A" is a true and correct copy of a document that was made at or near the time by or from information transmitted by a person with knowledge and kept in the regularly conducted business activity of the defendant and that it was the regular practice of the defendant to make such document. RESPONSE: Defendant objects to the compound nature of this Request. By way of further response: Denied. Defendant lacks sufficient knowledge and information DEFENDANT'S OBJECTIONS i RESPONSES TO PLAINTIFFS' request for admissions and request for PRC OUSTI ON TO DEFENDANTS - PAGE 213 concerning the origin and identity of the documents to admit or deny whether they are a true and correct copy of the originals, and this request is deemed denied. Request for Production No. 213: As to any documents listed on the attached Exhibit "A", which you claim is not a true and correct copy of a document that was made at or near the time by or from information transmitted by a person with knowledge and kept in the regularly conducted business activity of the defendant and that it was the regular practice of the defendant to make such document, in response to the foregoing Request, produce all documents which support your denial, in whole or in part . RESPONSE: Defendant objects to the compound and confusing nature of this Request. By way of further response, See Defendant's response to Request fcr Admission No. 211, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Request for Production No. 214: As to any documents listed on the attached Exhibit "A", which you claim is not a true and correct copy of a document that was made at or near the time by or from information transmitted by a person with knowledge and DEFENDANT' S OBJECTION'S i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRCO'JCTION TO DEFENDANTS - PAGE 214 kept in the regularly conducted business activity of the defendant and that it was the regular practice of the defendant to make such document, in response to the foregoing Request, produce any and all versions of such document, which you are willing to admit is a true and correct copy of a document that was made at or near the time by or from information transmitted by a person with knowledge and kept in the regularly conducted business activity of the defendant and that it was the regular practice of the defendant to make such document. RESPONSE: Defendant objects to the compound and confusing nature of this Request. By way of further response, See Defendant's response to Request for Admission No. 211, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Defendant further objects to this request on the grounds that the phrase "any and all versions of such documents" is overbroad, vague and undefined. Request for Admission No. 212: Admit that each and every document listed on the attached Exhibit "A" is a true and correct copy of a document found among the business records of the Defendant. RESPONSE: Denied. '.3PCS5-5 .3 PLAIN. IFF S ' REQUES. FOP. AEMISSIONS AND REQUEST FOR PAGE 215 Request for Production No. 215: As to any documents listed on the attached Exhibit "A", which you claim is not a true and correct copy in response to the foregoing Request, produce all documents which support your denial, in whole or in part. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Request for Production No. 216: As to any documents listed on the attached Exhibit "A", which you claim is not a true and correct copy in response to the foregoing Request, produce any and all versions of such document which you admit is a true and correct copy. RESPONSE: See Defendant's response to the cited Request for Admission, which is incorporated herein in response. Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to DEFENDANT'S OBJECT IONS i RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR ff.cccct:c:.- to defendants - page 216 be produced. Defendant further objects to this request on the grounds that the phrase "any and all versions of such documents" is overbroad, vague and undefined. Request for Production No. 217: If you contend that any of the documents described on the attached Exhibit "A" have in any manner been edited, purged, culled, changed, altered or in any other manner and/or made different from the way such records existed when created, produce all documents supporting your contention. RESPONSE: Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request cr. che grounds that it fails to identify with particularity the documents to be produced. Defendant further objects to this request on the grounds that the phrase "all documents" is both overbroad and undefined. By way of further response, See the deficiencies and additions apparent on the face of the document. Request for Production No. 218: As to any documents listed on che attached Exhibit "A", as to which you contend have in any manner been edited, purged, culled, changed, altered or in any other manner and/or made different from the way such records existed when created, produce any and all versions of such DEFENDANT'S OBJECTIONS & RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS AND REQUEST FOR PRODUCTION TO DEFENDANTS - PAGE 217 document that you contend has not been in any manner edited, purged, culled, changed, altered or in any other manner and/or made different from the way such record existed when created. RESPONSE: Defendant objects to this request on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of evidence admissible at trial in this matter. Defendant further objects to this request on the grounds that it fails to identify with particularity the documents to be produced. Defendant further objects to this request on the grounds that the phrase "any and all versions of such documents" is overbroad, vague and undefined. Request for Production No. 219: Produce all documents listed on the attached Exhibit "A" which are in your custody, possession or control. RESPONSE: Defendant objects to this request on the grounds that it is overly broad and unduly burdensome in that plaintiff's counsel is demanding copies of more than 200 documents that plaintiff already has in its possession, and most, if not all, of the documents have nocning to do with the issues in this case. CHS RESPONSES TO PLAINTIFFS' VEST FOR ADMISSIONS AND REQUEST FOR