Free Motion for Protective Order - District Court of Colorado - Colorado

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 1 of 10

SCHEDULE A SUBPOENA REQUEST NO. 1: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of, and likely to produce the same documents requested in, Request Nos. 15, 16, 17, 20, 23, 24, 25, 26, 44, 62 and 63 in Big-D' First Request for s Production of Documents. SUBPOENA REQUEST NO. 2: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle concerning the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Request No. 85 in Big-D' First Document Request. s The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 62, 63, 85, 86 and 87 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 3: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project.

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 2 of 10

COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Request No. 70 in Big-D' First Document Request. s The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 33, 34, 66, 67, 68, 71 and 72 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 4: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle that comprise, refer to, or concern written communication by and between Jack Towle and Big-D concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Request No. 15 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 5: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Leprino concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Request Nos. 23 and 35 in Big-D' First Document s Request. SUBPOENA REQUEST NO. 6: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 3 of 10

Bonelli and/or SJO concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Request Nos. 16, 17 and 25 in Big-D' First s Document Request. SUBPOENA REQUEST NO. 7: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and any other individual or entity concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 1. The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 15, 16, 17, 20, 25, 62 and 63 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 8: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Big-D concerning the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 2 and Request No. 85 in Big-D' First Document Request. The request is further repetitive of, and likely to s produce the same documents requested in Request Nos. 62, 63, 84, 85, 86 and 87 in BigD' First Document Request. s

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 4 of 10

SUBPOENA REQUEST NO. 9: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Leprino concerning the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 2 and Request No. 53 and 62. The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 63, 84 and 85 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 10: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to or concern written communication by and between Jack Towle and USA Tank concerning the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 2 and Request No. 85. The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 62, 63 and 84 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 11: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Global Industrial concerning the Wastewater Project.

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 5 of 10

COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 2 and Request No. 85. The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 62, 63 and 84 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 12: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to or concern written communication by and between Jack Towle and any other individual or entity concerning the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 2 and Request No. 85. The request is further repetitive of, and likely to produce the same documents requested in Request Nos. 62, 63 and 84 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 13: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Big-D concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of, and likely to produce the same documents requested in Subpoena Document Request No. 3 and Request Nos. 33, 34, 66, 67, 68, 70, 71 and 72 in Big-D' First Document Request. s

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 6 of 10

SUBPOENA REQUEST NO. 14: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Leprino concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request No. 53 in Big-D' First Document Request. The request is further repetitive of, s and likely to produce the same documents requested in Request Nos. 62, 63, 53, 68, 69, 70, and 71 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 15: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and Bonelli concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request Nos. 16, 17, 70 and 71. The request is further repetitive of, and likely to produce the same documents requested in Request No. 66 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 16: Any and all documents generated by or on behalf of, or received by, Jack Towle,

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 7 of 10

including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and SJO concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request Nos. 17 and 62 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 17: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and the vendors concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request No. 70 in Big-D' First Document Request. The request is further repetitive of, s and likely to produce the same documents requested in Request Nos. 33, 34, 66, 67, 68, 69 and 72. SUBPOENA REQUEST NO. 18: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, that comprise, refer to, or concern written communication by and between Jack Towle and any other individual or entity concerning the procurement, design or purchase of

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 8 of 10

processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request No. 70 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 19: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which refer to or otherwise concern any delays or timeline revisions, including the causes therefore, on the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request No. 1 and Request No. 36 in Big-D' First Document Request. The request is further repetitive of, and likely to s produce the same documents requested in Request Nos. 24 and 35 in Big-D' First s Document Request. SUBPOENA REQUEST NO. 20: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which refer to or otherwise concern any delays or timeline revisions, including the causes therefore, on the Wastewater Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 2 and Request No. 36 in Big-D' First Document Request. The request is further repetitive of, s and likely to produce the same documents requested in Request Nos. 24 and 35 in Big-

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 9 of 10

D' First Document Request. s SUBPOENA REQUEST NO. 21: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which refer to or otherwise concern any delays or timeline revisions, including the causes therefore, in the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request No. 36 and 70 in Big-D' First Document Request. The request is further s repetitive of, and likely to produce the same documents requested in Request Nos. 24 and 35 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 22: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which comprise internal notes or memoranda concerning the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 5 and Request No. 23 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 23: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which comprise internal notes or memoranda concerning the Wastewater Project.

Case 1:03-cv-02669-MSK-PAC

Document 97-2

Filed 07/22/2005

Page 10 of 10

COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 2 and 9 and Request No. 53 in Big-D' First Document Request. s SUBPOENA REQUEST NO. 24: Any and all documents generated by or on behalf of, or received by, Jack Towle, including those kept in the hard drive(s) of computer(s) used by Jack Towle, which comprise internal notes or memoranda concerning the procurement, design or purchase of processing equipment for the Cheese Factory Project. COMPARISON TO BIG-D' FIRST DOCUMENT REQUEST: S This request is repetitive of Subpoena Document Request Nos. 1 and 3 and Request No. 53 in Big-D' First Document Request. s