Free Motion to Compel - District Court of Arizona - Arizona

INCORPORATED BY REFERENCE FROM #47, PLAINTIFF'S MOTION TO COMPEL SUPPLEMENTAL DISCOVERY ANSWERS ­ INCLUDING ITS EXHIBITS, WHICH FURTHER INCLUDE PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO AVNET, INC. AND PLAINTIFF'S FIRST SET OF INTERROGATORIES TO AVNET, INC.; AND AVNET'S RESPONSES THERETO

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publications over the years that have no bearing on the instant lawsuit. Defendants
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further object to this Interrogatory on the grounds that it is vague and ambiguous by
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its directives to identify "methods utilized in the, preparation of all Avnet annual reports and Avnet-related publications" and "methods for using any of Plaintiffs
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photographs in any such report o r publication." Nonetheless and without waiving its objecitions, Avnet will respond to this Interrogatory with a description of how the phoiographs a t issue were selected to appear in Avnet's 2002 and 2003 Annual Report as well as Avnet's internal
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publication Avnet Global Perspective.

Avnet chief Communications Officer A1

Maag is responsible for selecting the images of Vallee to appear in Avnet's Annual Report. In determining which photographs to use, Maag reviews all of the
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photographs of Roy Vallee available to him and selects the one he likes best. He then directs either Avnet's Director of Creative S1ervices Javed Badar or Avnet Multimedia Services Director Bob Hackett to incoqporate the photograph he selected into the Annual Report. With respect to the photographs that appeared in Avnet Global Perspective, Avnet Director of Creative Services Javed Badar is responsible for the design and layout of the magazine, which includes selection of the photographs. Mr. Badar reports directly to Avnet Director of Employee

Communicati'ons Michele Spiegel but the selection of the photographs is left to Mr. Badard. Like Mr. Maag, Mr. Badar simply selects the photograph of Mr. Vallee he likes best and inserts it into the publication. Interrogatory No. 4: State the date (month, day, and year) and circumstances concerning Defendants' first use and all subsequent uses of Plaintiffs Photogiaphs of Roy Vallee and the manner
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and extent of such first and all subsequent uses, whether on an Avnet website, a Thirdparty website, or in any report or publication.

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