To: CHRISTINE who wrote (4153 ) 1/19/1999 1:47:00 PM From: CHRISTINE Read Replies (1) | Respond to of 4276
From AOL (CALFTALK)Re:vital data from ongoing lawsuits(second half) Date: 99-01-13 03:07:52 EST From: califtalk@aol.com (CALIFTALK) Interrogatory 28. Yarmak objects that the request is overbroad, vague and ambiguous and therefore unintelligible as it does not relate to specific facts. Yarmak further objects that the request violates the attorney client privilege and work product doctrine. Without waiving said objections, Yarmak in an attempt to reasonably respond submits the following: Yarmak incorporates his response to interrogatory 24, 25, 26 and 27 as if stated in full herein and adds: The audited financial statements of Caye Chapel, the press releases of Caye Chapel and the statement of attorney Warren Soloski and the Caye Chapel web site and conversations with employees of the Texas Railway Commission and conversations with Gary Giles, Gary Geer and Cliff Budd all provided the information listed in Exhibit "E." Interrogatory 29. Yarmak objects that the request is overbroad, vague and ambiguous and therefore unintelligible as it does not relate to specific facts. Yarmak further objects that the request violates the attorney client privilege and work product doctrine. Without waiving said objections, Yarmak in an attempt to reasonably respond submits the following: Yarmak incorporates his response to interrogatory 24, 25, 26, 27 and 28 as if stated in full herein and adds: The audited financial statements of Oilex, the press releases of Oilex, the Oilex web page, Oilex's 10-K and 10-Q filings, broker confirmations and wire transfers from securities sales in Canada. Interrogatory 30. Yarmak objects that the request is overbroad, vague and ambiguous and therefore unintelligible as it does not relate to specific facts. Yarmak further objects that the request violates the attorney client privilege and work product doctrine. Without waiving said objections, Yarmak in an attempt to reasonably respond submits the following: Yarmak incorporates his response to interrogatory 24, 25, 26, 27, 28 and 29 as if stated in full herein and adds: Statements by Stanley Griffin, Omar Ahmed, Willie Brown, Richard Clark, Deborah Sachery and Oliver Timmins and a letter from Oliver Timmins and the audited financial statements and financial reports of Oilex and stockbroker reports of Oilex and the records of BT Energy showing its transactions with Oilex in the acquisition of royalty interests. Documents 4. Yarmak objects that the request seeks public information available on the internet which Burditt has equal access to. In addition these documents are in the possession of attorney Warren Soloski who represents Burditt's other companies. Therefore the request is overbroad, burdensome and oppressive. Therefore no documents will be produced. In addition, Burditt prepared the majority of those press releases and he has copies of said releases. Documents 26. Discovery is continuing and Yarmak believes there will be additional documents in support of this contention. At this time the documents showing the trail of Oilex's funds to Phoenix Reserves then to escrow for the purchase of the property and the contract for the sale of the property establish Burditt's interest in the property through M. Patten Holdings. 6. Yarmak objects to the interrogatory as all other requested information is confidential and not reasonably calculated to lead to the discovery of admissible evidence. Yarmak specifically objects that his prior work experience is irrelevant to the allegations that he posted untrue unprivileged messages regarding Burditt. Omar informed Yarmak that Omar controlled the web page for Oilex and Caye Chapel. 13. Objection, vague and ambiguous and overbroad therefore unintelligible. In addition, the request calls for inforamtion protected by the work product doctrine and attorney client privilege. The request also impermissibly violates the rule against subparts. Without waiving said objections Yarmak responds that all assertions of fact that he has made have been truthful. Further, Yarmak has not improperly or otherwise taken any property from Burditt's residence. Objection, request is overbroad, vague, ambiguous, burdensome, oppressive and unintelligible as to "or made of." In addition, this information is equally available to Burditt. Without waiving said objections, Yarmak responds that prior to Yarmak's becoming president of Oilex, all Oilex press releases, financial statements, web pages, Oilex policy statements, presentations were all controlled and therefore made by Burditt. In addition, these same communications made by Caye Chapel, BT Energy, Phoenix Reserves, M. Patten Holdings and Churchill Resources were also made by Burditt. Requiring this multitute of statements to be transcribed is truly burdensome and oppressive.