Free Response in Opposition to Motion - District Court of Arizona - Arizona

EXHIBIT A
Case 2:04-cv—OO384—ROS Document 575-2 Filed O7/O2/2008 Page1 0f3

Exhibit Marked Admitted
N0. for ID _In Description Objection
Evidence
It is noted, however, that
Meritage assumes that it
has reviewed the correct
document. In this respect,
Hancock hz? failed toc
comp y wit Fed. R. iv.
P. 26(a)’s express
requirement of an
“appropriate identification
fglegijch dolc;1me1Â¥for
e 1 it." ainti s
rgquesited such I b
1 ent1 1cation on y to e
told that Hancock would
not so com l .
5 5 3_ Meritage Response to Greg Ob~l°°tl°n‘ Thqsc mcludc
naaaaak·S saama lgeal and tcchcylcal ld b
Requests for Production of g0§,$12§1*§t2“th;N%LIg/ °
D°°“‘“°“l*‘· Fac. R. Evra. 40%. (ir
there is a representation
from the Responses that
Hancock see s to admit,
we will consider an
appropriate stipulation.)
It is noted, however, that
Meritage assumes that it
has reviewed the correct
document. In this respect,
Hancock has failed to
coréiéiljg with Fed. R. Civ.
P. a ’s express
re uirement of an
appropn 1on
" q `ate identificatf
fo each document or
exhibit.’;1Plai1ntiffs
requeste suc
identification only to be
told that Hancock would
not so com l .
5 59_ Meritage Complaint vs. Ob. t. Th. . d ft
Titus, Brueckner, et. al., J6? 191*;*th tls IS a ra
cv2006-00492 (Maricopa 90lgP in tl adltla? d
County) ma ve en y 150 ose
and remams subject to the
attome -client rivile e.
9/30/05 rt 1 . . . .
56°‘ sam Qlifé il Olvmn- The
204l8B6.3
Case 2:04-cv—OO384—ROS Document 575-2 Filed O7/O2/2008 Page 2 of 3

Exhibit Marked Admitted
No. for ID Evigigncc Description Obj eetien
Activities report; from company
counsel about the status of
certain litigation matters
under the responsibility of
certain employees within
a Division of Meritage
and remains subject to the
attorne -client rivile e.
56l' éggiggggggrlal L‘“ga"°“ Objection. It should be
noted that Plaintiffs are
unsure which specific
document Hancock is
referring In this respect,
Hancoc has failed to
comgly with Fed. R. Civ.
P. 2 (a)’s express
requirement of an
"appropriate identification
fo each document or
exhibit." Plaintiffs
requested such
identification only to be
told that Hancock would
not so com l .
562_ I2/14/04 Article from . .
Arizona Re ublic Business Objection Nol Sum what
Buzz, awelj) Street document this is referring
Darlings" t°·
In this respect, Hancock
has failed to com ly with
Fed. R. Civ. P. 2d)(a)’s
express requirement of an
"appropriate identification
fo each document or
exhibit." Plaintiffs
requested such
identification only to be
told that Hancock would
not so com i .
563- g’§,Q$gmgg;;1gSfS§,§{g;¤0¤k The eyieeeee as eeeleeee
U S Keeps and misleading for the
' ' reasons set forth in
Plaintiffs’ Motion in
Limine re Testimony and
Argument that Plaintiffs
P ortedl Stole
204l8E6.3
Case 2:04-cv—OO384—ROS Document 575-2 Filed O7/O2/2008 Page 3 of 3

Case 2:04-cv-00384-ROS

Document 575-2

Filed 07/02/2008

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Case 2:04-cv-00384-ROS

Document 575-2

Filed 07/02/2008

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Case 2:04-cv-00384-ROS

Document 575-2

Filed 07/02/2008

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