http://www.kccllc.net/documents/0812229/0812229110203000000000006.pdf
PSD pg # 8
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2. The Equity Committee’s Discovery is Not Overly Broad, Burdensome, Meant to Delay or Intended to Harass.
9. The Settlement Note Holders implausibly argue that the discovery requests are “Staggeringly broad,” burdensome and designed to cause delay. See e.g., Owl Creek Objection, pp32-35. This objection is meritless and is inconsistent with the Settlement Note Holders’ prior representation to the Court. At the last hearing, the Settlement Note Holders persuaded this court to defer its hearing on these discovery requests on their promise that, if the hearing was deferred until February, the Settlement Note Holders would be able to comply with our discovery requests within two weeks.
THE COURT: Well, if I grant the discovery will you be providing it to them within thirty days, as suggested, by then: Two weeks for documents and two weeks for deposition. So by the end of February – well, the first week of March, they have everything so they can prepare for confirmation?
MR. WITZEL: The short answer is we hope we don’t have to get there. But obviously, whatever the Court – the answer is we’ll - the answer is yes, if that’s – we’ll do everything we can to follow that schedule.
(Jan. 20, 2011 Trans. At 77).6 As such, the Settlement Note Holders should not now be permitted to argue that the requests are too broad for them to comply with them within a reasonable time period.
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Talk about using one's words against them... ;^) I'm growing to love Susman & Associates' filings. Clear, concise, to the point... like a pro boxer's double jab, right cross, left hook, right uppercut (fight over!).