REQUEST NO. 8:
All Documents concerning Your alleged medical condition of anhidrosis, hypohidrosis, or
Your inability to sweat.
7147-2
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RESPONSE TO REQUEST NO. 8:
In addition to the General Objections, which are incorporated herein by this reference,
Defendant objects to this Request to the extent that it is argumentative and seeks documents subject to the attorney-client privilege or work-product protection. Defendant objects to this Request on the grounds that it is harassing and seeks confidential and private information and documents that are irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence. Defendant additionally objects to this Request as premature (1) because the parties have not executed nor has the Court entered a protective order in this action sufficient to safeguard the confidentiality of documents and information produced by the parties in the course of discovery; and (2) because until the threshold issue of the Court’s subject matter jurisdiction over this matter, discovery other than on the narrow topic of Plaintiff’s domicile is improper.
Subject to and without waiving the foregoing objections, Defendant responds as follows:
Defendant is unable to comply with Request No. 8 because no such documents exist in his possession, custody or control. A diligent search and a reasonable inquiry have been made in an effort to comply with this demand.
Dated: December 27, 2021 Los Angeles, California
Respectfully submitted, LAVELY & SINGER, P.C.
s/ Melissa Y. Lerner
Andrew B. Brettler (AB2662) Melissa Y. Lerner (pro hac vice) 2049 Century Park East, Suite 2400 Los Angeles, California 90067 Telephone: (310) 556-3501 Facsimile: (310) 556-3615
Email:
[email protected] Email:
[email protected]
Attorneys for Prince Andrew, the Duke of York
https://storage.courtlistener.com/recap/gov.uscourts.nysd.564713/gov.uscourts.nysd.564713.60.2.pdf