DEFENDANT’S REQUEST FOR PRODUCTION OF （被告的要求生产的）.pdf

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 08-K-339 RADIO SHED, INC., a Colorado Corporation, Plaintiff, v. AMERICAN ELECTRONICS, Inc., a Nevada Corporation, Defendant. ________________________________________________________________________ DEFENDANT’S REQUEST FOR PRODUCTION OF DOCUMENTS TO: Plaintiff Radio Shed, Incorporated (RSI) by and through its attorney of record, Jeff Howell, DU Law Firm, 2255 E. Evans Avenue, Denver, Colorado 80208. INSTRUCTIONS 1. Pursuant to Rule 34 of the Federal Rules of Civil Procedure (FRCP), Defendant American Electronics, Incorporated (American) submits the following request for production of documents from Plaintiff RSI. 2. Pursuant to FRCP Rule 34(a), Defendant acknowledges that these requests are limited to the scope of FRCP Rule 26(b), and requests that when Plaintiff is unable to produce certain documents because they fall outside of such scope, Plaintiff will provide a brief explanation as to the reason why the documents fall outside the scope of the request. 3. If certain requests are duplicative of previous requests to which documents have already been produced, Plaintiff need not reproduce such documents but is requested to notify Defendant that such documents are among those already produced. 4. Pursuant to FRCP Rule 34(b)(2)(E), Defendant requests that when Plaintiff does produce the requested documents, including electronically stored information (ESI), Plaintiff will produce such documents or ESI as they are kept in the usual course of business or will organize and label them to correspond to the categories in the request. 5. Defendant requests that Plaintiff make a good faith effort to produce any