변호사 이재욱의 미국법 이야기 (Attorney Lee's commentary about U.S. law)

DOCUMENT REQUESTS
1. Any and all written correspondence between RSI and United Parcel Service (UPS)
between March 1, 2007 and the present date that relate directly to the April 1, 2007
contract between said parties for 2,000 GMUs.
2. Any and all records of oral communication between RSI and UPS between March
1, 2007 and the present date that relate directly to the contract described in Request
#1.
3. Any and all internal communication between March 1, 2007 and the present date
between any of the following parties: Dana Fitzgerald, Terry Cummings, and Dale
Jordan, relating to the UPS contract described in Request #1.
4. Any and all internal communication between any of the following parties: Dana
Fitzgerald, Terry Cummings, and Dale Jordan, relating to the agreement with
American from April 22, 2007 that involved the 2,000 transmitters for the UPS
contract described in Request #1, that are not duplicative of those documents
produced pursuant to Request #2.
5. Any and all communication between the sales and/or production departments at
RSI and the receiving department at RSI that directly relate to the 2,000
transmitters shipped from American to RSI for the UPS contract described in
Request #1.
6. Any and all bills of lading, shipping receipts, inventory lists, and documentation by
the RSI receiving department and/or production department that reflect the date,
time and recipient at RSI of the delivery of the American shipment of 2,000
transmitters that were shipped pursuant to the April 22, 2007 agreement in dispute.
7. RSI production schedules for the months of July, August, September, and October
for the division(s) of the RSI production department that handled or would have
handled production and/or assembly of the GMUs for the UPS contract described in
Request #1.
8. Any and all written communication between RSI and the third party vendor(s) that
was/were contracted to supply transmitters to RSI for the UPS contract described in
Request #1, that relates directly to the supply of the 2,000 transmitters that RSI
required to fulfill the UPS GMU order in the April 1, 2007 contract.
9. Any and all records of oral communication between RSI and the third party vendor
(s) that was/were contracted to supply transmitters to RSI for the UPS contract
described in Request #1, that relate directly to the supply of the 2,000 transmitters that RSI required to fulfill the UPS GMU order in the April 1, 2007 contract.
10. Any and all written communication or records of oral communication between RSI
employees, dated between July 3, 2007 and the date at which RSI shipped the
GMUs to UPS pursuant to the contract described in Request #1, that relate directly
to the 2,000 transmitters supplied by third party(ies) to replace the transmitters that
were originally shipped by American pursuant to the April 22, 2007 agreement in
dispute.
11. Any and all modified agreements/amendments/addendums to the contract between
RSI and UPS originally dated April 1, 2007.
12. Any internal records of written or oral communication between or among RSI
employees dated between May 1, 2007 and the present date that mention or discuss
cessation or interruption of future business with or bid solicitation from American.
13. If not already included among the documents produced pursuant to Requests #1
through 11, copies of any and all documents or records dated April 22, 2007 to the
present, that mention, discuss, or describe mistakes and/or errors that American
and/or RSI may have made between April 3, 2007 and December 15, 2007 that
directly relate to the UPS contract described in Request #1.
14. Any documents, records, or communication between UPS and RSI that mention,
discuss, or negotiate damages, fees, mitigation of delays, and staggered delivery
dates that relate directly to the 2,000 GMUs ordered by UPS pursuant to the
contract described in Request #1.
15. Any internal communication records between and among RSI employees that
mention, discuss, or analyze production options to mitigate delays and stagger
delivery dates, including any cost/benefit analysis of the options.
16. Any documents or written records generated from or summarizing oral discussions
with Kelly Curtis and/or any other American employee between the dates of April
1, 2007 and the present date that relate to the UPS contract described in Request #1,
the agreement between RSI and American for the 2,000 transmitters in dispute, or
any subsequent business dealings.
17. If not already included, the memorandums between Terry Cummings and Dana
Fitzgerald dated April 22, 2007, July 3, 2007, and August 27, 2007, all of which
were described in Plaintiff’s Response Number 12 to Defendants Interrogatories
dated September 25, 2008.Dated: October 1, 2008 Respectfully submitted,
/s/ Blair
Henton
 Blair Henton, Esq.
 Attorney for Defendant
 3600 Las Vegas Boulevard South
Las Vegas, Nevada 89109.