RESPONSESTO INTERROGATORIES
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INTERROGATORY NO.1:illENTIFY every copyright at issue n this suit, including a completechronological5recordof the registration,ownership, icenseand/or assignment f that copyright.
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RESPONSE TO INTERROGATORY NO.1:Plaintiffs object o this interrogatoryon the grounds hat it is overbro~ compound,and
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calls for infonnation that is not relevant o any claim or defense n the action, and t is
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oppressive, urdensome nd harassing.Plaintiffs also object o the phrase completechronological ecord" as vagueand ambiguous. Without waiving any objections,Plaintiffs will112provide copiesof the Certificatesof Registration or eachsound ecording isted on Exhibit A to
13the Complaint.1415INTERROGATORY NO.2:16mENTIFY every communication,written or oral, that You have had with any hird party,
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including but not limited to Comcast, egarding nfringing conductat issue n this suit, including18but not limited to the namesof the people nvolved in the communication, he dateand ime of19the communication,and subjectmatterof eachcommunication.
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21RESPONSE TO INTERROGATORY NO.2:Plaintiffs object o this interrogatoryon the grounds hat it is compoundand calls for
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information protectedby the attorneyclient privilege and/or he work product doctrine.
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Plaintiffs also object to the phrase third-party" as vagueand ambiguous. Without waiving their
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objections,pursuant o FederalRule 33(d), Plaintiffs wiII produceall correspondence ith
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Comcastspecifically relating to Defendant.
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