RE: Court documents26 Dec 2018 15:57
The court order does not appear to give Hope any way to avoid discovery.
B. Instructions
1. The provisions of Fed. R. Civ. P. 26, 34, and 45 are incorporated by reference.
2. These Document Requests cover all documents and information in Hope’s possession, custody, or control, including, but not limited to, information in the possession of Hope’s employees, agents, servants, representatives, attorneys, or other persons directly or indirectly employed or retained by Hope, or anyone else acting on Hope’s behalf or otherwise subject to Hope’s control.
3. If objection is made to producing any document, or any portion thereof, or to disclosing any information contained therein, in response to any Request on the basis of any claim of privilege, provide a statement setting forth the information required by Fed. R. Civ. P. 26(b)(5)(A).
4. Unless otherwise noted, the relevant time period for these Requests shall be January 1, 2018 to the present.
5. The requested documents are to be produced no less than two weeks prior to the deposition.
C. Requests for Documents
1. All documents concerning Hope’s efforts, if any, to obtain (or assist others to obtain) funding for FRC from investment banks, private investors, and other sources of capital.
2. All documents concerning any proposal to sell off some or all of FRC or the group of companies composed of FRC and its subsidiaries.
3. All documents exchanged by and between any of Hope, OMF, and Outrider Management concerning FRC or FIC.
4. All documents exchanged between Hope, OMF, or Outrider Management and Cairn Financial Advisers LLP concerning FRC or FIC.
5. All documents exchanged between Hope, OMF, or Outrider Management and MND, Inc. concerning FRC or FIC from January 1, 2014 to the present.