PACER digEcor 337 Text
posted on
Apr 15, 2009 07:03PM
The following 6 paragraphs in 337 are followed by a 48 page list of items in table format. If all else fails I will copyand paste even though the format will be all screwed up. You'll get the idea.
____________________________________...
Defendants e.Digital Corporation, William Blakeley, and Fred Falk ("e.Digital") submit their Objections to digEcor’s Supplemental Rule 26(a)(3) disclosures.
e.Digital generally objects to the vague and non-specific designations made by digEcor in violation of the Federal Rules of Civil Procedure. Many of digEcor’s designations do not identify the designated document with sufficient specificity for e.Digital to locate the document, let alone to enter proper objections thereto. These objectionably vague and overbroad designations include, but are not limited to, exhibits 133-144, 173, 174, of those digEcor expects to introduce, and exhibits 171-175 of those digEcor may introduce. E.Digital reserves the right
to enter any and all objections to any exhibits that have not been specifically designated by digEcor, and affirmatively objects to digEcor’s use of non-specific and overbroad designations. In the event that digEcor’s broad designations are accepted by the Court, however, e.Digital reserves its right to use as exhibits and take full advantage of all of these broad categories of documents as well.
e.Digital also objects to the designations of Derk Rasmussen and Paul Hepworth as witnesses, to the extent that either witness is unable to satisfy the requirements for expert testimony under Fed. R. Evid. 702, 703 and related caselaw.
Further, e.Digital reserves its objections to each transcript designated by digEcor. E.Digital will enter specific objections in connection with the specific testimony cited at the time stated by the parties for the exchange of page and line designations of transcripts, on April 24, 2009.
e.Digital makes specific objections to the exhibits designated by digEcor as follows: