EFTA01378428.pdf

Page 6 2009 U.S. Dist. LEXIS 29508, * Interrogatory No. 2.09: A verified supplemental interrogatory response shall be provided identifying the documents which have been produced which provide the information responsive to this interrogatory (or referencing the February 16, 2009 letter identifying those documents if the letter identifies the specific documents which contain all information responsive to this interrogatory) and stating that the response is complete. Interrogatory No. 2.10: A verified supplemental interrogatory response shall be provided identifying the documents which have been produced which provide the information responsive to this interrogatory (or referencing the February 16, 2009 letter identifying those specific documents if the letter identifies the documents which contain all information responsive to this interrogatory) and stating that the response is complete. Interrogatory No. 6 and Request for Production No. 3: A verified supplemental interrogatory response [*1 2] shall be provided identifying the documents which have been produced which provide the information responsive to this interrogatory and Request For Production No. 3 and an indication that the documentation is all of the responsive documentation in the possession, custody, or control of the defendant. Interrogatory No. 8: The Motion is passed over, as Takata has agreed to provide a supplemental response repeating the information already provided and stating that the response is complete. Interrogatory No. 9 and Request No. 4: The Takata Defendants already responded in a verified response that they are not aware of any agreement or contract entered into with General Motors in connection with the design or testing of the seat belt restraint system at issue in this litigation. See Takata Defs.' Resp. at Interrog. No. 9. The Takata Defendants are to determine if any general agreements exist which would encompass the design or testing of the seat belt restraint system involved in this litigation and produce any applicable agreements. If such agreements exist, but contain information unrelated to the seat belt restraint system at issue, the Takata Defendants may approach the court, after consulting ['13] with plaintiffs, about redacting such non-responsive information prior to production. Interrogatory No. 10: A verified supplemental interrogatory response shall be provided which identifies all individuals involved in the responsive testing, or it shall indicate that those individuals are identified in identified in documents previously produced. Interrogatory Nos. 11 and 12 and Request for Production Nos. 5 and 6: A verified supplemental interrogatory response shall be provided identifying the documents which have been produced which provide the information responsive to this interrogatory (or referencing the February 16, 2009 letter identifying those specific documents if the letter identifies the documents which contain all information responsive to this interrogatory) and stating the response is complete. Interrogatory No. 13 and Request for Production No. 7: The Motion is denied without prejudice as to Interrogatory No. 13 and Request for Production No. 7. Interrogatory No. 14 and Request for Production No. 8: A verified supplemental interrogatory response shall be provided identifying the documents which have been produced which provide the information responsive to this interrogatory ["14] and Request For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0075607 CONFIDENTIAL SDNY_GM_00221791 EFTA01378428