Preview
Exhibit 43CAUSE NO. 2017-43835
SAM ALAM, IN THE DISTRICT COURT
Plaintiff,
we 165th JUDICIAL DISTRICT
ANDREW GOMES, MD;
MAHENDRA AGRAHARKAR, MD;
AJAY CHOUDHRY, MD;
NATIONAL INTERVENTIONAL
RADIOLOGY PARTNERS, PLLC;
NIRP MANAGEMENT, LLC,
NIRP PASADENA, PLLC,
NIRP SUGARLAND, PLLC,
Defendants.
OD LR LP LP LD UD UD LD En OD LD OD
HARRIS COUNTY, TEXAS
DEFENDANT ANDREW GOMES, MD’S OBJECTIONS AND RESPONSES TO
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
To: Sam Alam, Pro Se Plaintiff, P.O. Box 295, Bellaire, Texas 77401
In accordance with the Texas Rules of Civil Procedure, Defendant Andrew Gomes, MD
(“Gomes”) hereby submits his responses to Plaintiff's First Request for Production.
Respectfully submitted,
BAKER, DONELSON, BEARMAN,
CALDWELL & BERKOWITZ
A Professional Corporation
By: _/s/ Kenneth E. McKa
Kenneth E. McKay
SBN: 13690835
kmckay@bakerdonelson.com
BAKER, DONELSON, BEARMAN,
CALDWELL & BERKOWITZ. P.C.
1301 McKinney Street
Suite 3700
Houston, Texas 77010
713.650.9700 - Telephone
713.650.9701 - Facsimile
Attorneys for Defendants
4823-8681-8127 v1
2934734-000003 12/04/2017CERTIFICATE OF SERVICE
J hereby certify that on December 4, 2017, a true and correct copy of the foregoing was
served on all Pro Se parties and counsel of record pursuant to the Texas Rules of Civil
Procedure.
Sam Alam, Pro se VIA CMRRR 7017 2400 0000 6155 5265
POB 295
Bellaire, Texas 77054
samalam2@gmail.com
713.385.7979 - Telephone
/s/ Kenneth E. McK
Kenneth E. McKay
4823-8681-8127 vI
2934734-000003 12/04/2017RESPONSES TO REQUESTS FOR PRODUCTION
Ls Copy of all Insurance Policies in which “you” have individual coverage from
liabilities.
Response: Defendant objects to this request as not reasonably calculated to lead to
admissible evidence.
2: Copies of “your” personnel file pertaining to the defendant companies containing
documents including letters, correspondences, emails, and records for period 2014 to present
date.
Response: Defendant objects to this request as the term "personnel file" is vague,
ambiguous and undefined in the context of this lawsuit. Defendant further objects to the scope
of the request as not limited in time to the subject matter of this lawsuit. Defendant further
objects as the subject matter is not limited to the subject matter of this lawsuit and is, therefore,
overbroad.
3; All documents that reflect, discuss or contain any communication written, oral,
electronic or otherwise between “you” and Sam Alam for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad,
4. All documents that reflect, discuss or contain any communication written, oral,
electronic or otherwise between “you” and any and all shareholders/partners of the named
defendants in this lawsuit pertaining to Sam Alam for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
5; All documents that reflect, discuss or contain any communication written, oral,
electronic or otherwise between “you” and “anyone” pertaining to Sam Alam for period 2014 to
present date.
Response; Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
6. All documents that reflect, discuss or contain any communication written, oral,
electronic or otherwise between “you” and “anyone” including shareholders and partners of the
named defendants in this lawsuit regarding business plans, financial plans, and/or any and all
documents prepared and provided by Sam Alam for period 2014 to present date.
4823-8681-8127 v1
2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
ie All documents “you” offered and/or provided to “anyone” including shareholders
and partners of the named defendants in this lawsuit regarding “Casper Radiology” for period
2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit. .
8. All documents “you” offered and/or provided to “anyone” including shareholders
and partners of the named defendants in this lawsuit regarding “defendant companies” for period
2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
: All documents you received from anyone/person concerning defendant companies
from 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
10. All documents you received from anyone/person concerning Sam Alam from
2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
11. All documents, meeting minutes or notes prepared prior to, during, and after the
formation of the defendant companies for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
12. All documents, meeting minutes, notes between “you” and defendant Mahendra
Agraharkar regarding Sam Alam for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
4823-8681-8127 v1
2934734-000003 12/04/201713. All documents, meeting minutes, notes between “you” and defendant Ajay
Choudhry regarding Sam Alam for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad, Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
14. All documents, meeting minutes, notes between “you” and defendant National
Interventional Radiology Partners, PLLC for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
1S: All documents, meeting minutes, notes between “you” and defendant National
Interventional Radiology Partners, Management, LLC for period 2014 to present date,
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the tequest as not
limited in time to the subject matter of this lawsuit.
16. All documents, meeting minutes, notes between “you” and defendant Nationa!
Interventional Radiology Partners, Pasadena, LLC for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
17. All documents, meeting minutes, notes between “you” and defendant National
Interventional Radiology Partners, Sugarland, LLC for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
18. All documents “you” gave and received from Jon D. Spiers, attorney at law and
anyone/person associated with Jon D. Spiers for period 2014 to present date,
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
19. All documents “you” gave and received from Reimer, McGuiness & Associates,
CPA and anyone/person associated with Reimer, McGuiness & Associates, CPA for period 2014
to present date.
4823-868 1-8127 v1
2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
20. All documents which reflect, discuss or contain any communication between you
and any Person or Organization concerning Sam Alam and/or anyone associated with Sam Alam
and/or the subject matter of this Lawsuit.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
21. All documents that were sent to “you” you or received by you from Sam Alam,
for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
22. All documents that would show and attest to “your” experience, qualifications,
education, and skills related to healthcare strategy, development of business plans, financial
plans, tactical plans, reimbursement plans, facility plans, architectural plans, and feasibility
studies related to the services that defendant companies now offer.
Response: Defendant objects to this request as not calculated to lead to admissible
evidence, seeking expert witness discovery in an impermissible form and not limited to the
subject matter of this lawsuit.
23. All documents that would show your skills, experience and business capabilities
with respect to forming health related entities providing services as offered by the defendant
companies prior to year 2014.
Response: Defendant objects to this request as not calculated to lead to admissible
evidence, seeking expert witness discovery in an impermissible form and not limited to the
subject matter of this lawsuit. Defendant further objects to the scope of the request as not limited
in time to the subject matter of this lawsuit.
24. All documents that were sent to “you” you or received by you from
Drisonline.com for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
25. All documents that were sent to “you”, you or received by you from defendants
Mahendra Agraharkar for period 2014 to present date.
4823-8681-8127 v1
2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit. Defendant further objects as duplicative.
26. All documents, meeting minutes, notes between “you” and any and all
shareholders and partners of NIRP for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
27. All documents that were sent to “you” you or received by you from Hashmet
Wali, Wali & Associates, and/or Robin Jacoby for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the acops of the request as not
limited in time to the subject matter of this lawsuit.
28. All documents including but not limited to Articles of Organization for all
defendant companies in which your name appears in for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
29. All documents including but not limited to all Agreements pertaining to all
defendant companies in which your name appears in for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad, Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
30. All documents pertaining directly or indirectly to the defendant companies for
period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
31. All agreements, contracts, shareholdings, partnership documents, letters of
understanding, equity participation, ownership interest, and guarantees by and between you and
all partners regarding the defendant companies from inception to date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
4823-8681-8127 vi
2934734-000003 12/04/201732. All documents related to architectural, engineering, site plans, design and
drawings pertaining to defendant companies from inception to date.
Respo! nse: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
33. All documents related to any statements (signed or otherwise) from any individual
regarding the subject matter of this action.
Response: As the term "statement" is defined in the Texas Rules of Civil Procedure,
none.
34, All documents relied upon by you in answering the Requests for Production
propounded to you in this action.
Response: In addition to work produce and attorney-client privilege, Defendant objects to
this request as beyond the scope of permissible discovery.
35. All documents related to attorney fee agreements entered into by you regarding
this lawsuit.
Response: Defendant objects to this request as beyond the scope of permissible
discovery as not reasonably calculated to lead to admissible evidence.
36. All documents evidencing attorney fee agreements entered into by you regarding
the formation of companies with provision to services now being offered by the defendant
companies from inception to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
37. All documents, which support and/or provide evidence of each of your alleged
denial herein.
Response: Defendant objects to this request as vague, ambiguous and undefined.
Defendant has no understanding of what denial, if any, this request concerns,
38. All documents, which support and/or provide your interest in each of the
defendant companies from 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
39. All documents, showing share certificate(s) you own pertaining to the defendant
companies from inception to present date.
4823-8681-8127 v1
2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
40, All tape recordings of any person having knowledge of arvy facts relating to the
subject matter of this Lawsuit.
Response: Defendant has not tape recordings of any matters pertinent to the subject
matter of this lawsuit as Defendant understands it.
41. All photographs, video or moving pictures relating to the subject matter of this
Lawsuit.
Response: Defendant objects to this request as overbroad.
42. All Witness Statements made in tangible (written or otherwise recorded or
memorialized) from by any person relating to the subject matter of this Lawsuit.
Response: Defendant objects to this request as duplicative. Subject to the foregoing
objection, none
43, All documents reflecting or concerning any agreement you have reached with
anyone relating, in whole or in part, to the subject matter of this Lawsuit.
Response: Defendant objects to the request as vague, ambiguous and overbroad.
Defendant further objects to the scope of the request as not limited in time to the subject matter
of this lawsuit.
44. All documents which you received from, or took from Plaintiff and which you
sent, gave or otherwise provided to any third party.
Response: Defendant objects to this request as duplicative. Defendant objects to the
request as not limited to the subject matter of this lawsuit and is, therefore, overbroad.
Defendant further objects to the scope of the request as not limited in time to the subject matter
of this lawsuit.
45. All documents which reflect, discuss contain any communications between you
and Plaintiff.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
46. All documents which you received from, or took from, any Person that concen
Sam Alam.
4823-8681-8127 v1
2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
47. — All documents pertaining to your business and financial plans including drafts
from inception to date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
48. All documents that were sent to “you” you or received by you from defendants
Ajay Choudhry for period 2014 to present date.
Response: Defendant objects to the request as not limited to the subject matter of this
lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not
limited in time to the subject matter of this lawsuit.
10
4823-868 1-8127 vi
2934734-000003 12/04/2017
Preview
Exhibit 43CAUSE NO. 2017-43835 SAM ALAM, IN THE DISTRICT COURT Plaintiff, we 165th JUDICIAL DISTRICT ANDREW GOMES, MD; MAHENDRA AGRAHARKAR, MD; AJAY CHOUDHRY, MD; NATIONAL INTERVENTIONAL RADIOLOGY PARTNERS, PLLC; NIRP MANAGEMENT, LLC, NIRP PASADENA, PLLC, NIRP SUGARLAND, PLLC, Defendants. OD LR LP LP LD UD UD LD En OD LD OD HARRIS COUNTY, TEXAS DEFENDANT ANDREW GOMES, MD’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION To: Sam Alam, Pro Se Plaintiff, P.O. Box 295, Bellaire, Texas 77401 In accordance with the Texas Rules of Civil Procedure, Defendant Andrew Gomes, MD (“Gomes”) hereby submits his responses to Plaintiff's First Request for Production. Respectfully submitted, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ A Professional Corporation By: _/s/ Kenneth E. McKa Kenneth E. McKay SBN: 13690835 kmckay@bakerdonelson.com BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ. P.C. 1301 McKinney Street Suite 3700 Houston, Texas 77010 713.650.9700 - Telephone 713.650.9701 - Facsimile Attorneys for Defendants 4823-8681-8127 v1 2934734-000003 12/04/2017CERTIFICATE OF SERVICE J hereby certify that on December 4, 2017, a true and correct copy of the foregoing was served on all Pro Se parties and counsel of record pursuant to the Texas Rules of Civil Procedure. Sam Alam, Pro se VIA CMRRR 7017 2400 0000 6155 5265 POB 295 Bellaire, Texas 77054 samalam2@gmail.com 713.385.7979 - Telephone /s/ Kenneth E. McK Kenneth E. McKay 4823-8681-8127 vI 2934734-000003 12/04/2017RESPONSES TO REQUESTS FOR PRODUCTION Ls Copy of all Insurance Policies in which “you” have individual coverage from liabilities. Response: Defendant objects to this request as not reasonably calculated to lead to admissible evidence. 2: Copies of “your” personnel file pertaining to the defendant companies containing documents including letters, correspondences, emails, and records for period 2014 to present date. Response: Defendant objects to this request as the term "personnel file" is vague, ambiguous and undefined in the context of this lawsuit. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. Defendant further objects as the subject matter is not limited to the subject matter of this lawsuit and is, therefore, overbroad. 3; All documents that reflect, discuss or contain any communication written, oral, electronic or otherwise between “you” and Sam Alam for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad, 4. All documents that reflect, discuss or contain any communication written, oral, electronic or otherwise between “you” and any and all shareholders/partners of the named defendants in this lawsuit pertaining to Sam Alam for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 5; All documents that reflect, discuss or contain any communication written, oral, electronic or otherwise between “you” and “anyone” pertaining to Sam Alam for period 2014 to present date. Response; Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 6. All documents that reflect, discuss or contain any communication written, oral, electronic or otherwise between “you” and “anyone” including shareholders and partners of the named defendants in this lawsuit regarding business plans, financial plans, and/or any and all documents prepared and provided by Sam Alam for period 2014 to present date. 4823-8681-8127 v1 2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. ie All documents “you” offered and/or provided to “anyone” including shareholders and partners of the named defendants in this lawsuit regarding “Casper Radiology” for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. . 8. All documents “you” offered and/or provided to “anyone” including shareholders and partners of the named defendants in this lawsuit regarding “defendant companies” for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. : All documents you received from anyone/person concerning defendant companies from 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 10. All documents you received from anyone/person concerning Sam Alam from 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 11. All documents, meeting minutes or notes prepared prior to, during, and after the formation of the defendant companies for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 12. All documents, meeting minutes, notes between “you” and defendant Mahendra Agraharkar regarding Sam Alam for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 4823-8681-8127 v1 2934734-000003 12/04/201713. All documents, meeting minutes, notes between “you” and defendant Ajay Choudhry regarding Sam Alam for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad, Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 14. All documents, meeting minutes, notes between “you” and defendant National Interventional Radiology Partners, PLLC for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 1S: All documents, meeting minutes, notes between “you” and defendant National Interventional Radiology Partners, Management, LLC for period 2014 to present date, Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the tequest as not limited in time to the subject matter of this lawsuit. 16. All documents, meeting minutes, notes between “you” and defendant Nationa! Interventional Radiology Partners, Pasadena, LLC for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 17. All documents, meeting minutes, notes between “you” and defendant National Interventional Radiology Partners, Sugarland, LLC for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 18. All documents “you” gave and received from Jon D. Spiers, attorney at law and anyone/person associated with Jon D. Spiers for period 2014 to present date, Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 19. All documents “you” gave and received from Reimer, McGuiness & Associates, CPA and anyone/person associated with Reimer, McGuiness & Associates, CPA for period 2014 to present date. 4823-868 1-8127 v1 2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 20. All documents which reflect, discuss or contain any communication between you and any Person or Organization concerning Sam Alam and/or anyone associated with Sam Alam and/or the subject matter of this Lawsuit. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 21. All documents that were sent to “you” you or received by you from Sam Alam, for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 22. All documents that would show and attest to “your” experience, qualifications, education, and skills related to healthcare strategy, development of business plans, financial plans, tactical plans, reimbursement plans, facility plans, architectural plans, and feasibility studies related to the services that defendant companies now offer. Response: Defendant objects to this request as not calculated to lead to admissible evidence, seeking expert witness discovery in an impermissible form and not limited to the subject matter of this lawsuit. 23. All documents that would show your skills, experience and business capabilities with respect to forming health related entities providing services as offered by the defendant companies prior to year 2014. Response: Defendant objects to this request as not calculated to lead to admissible evidence, seeking expert witness discovery in an impermissible form and not limited to the subject matter of this lawsuit. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 24. All documents that were sent to “you” you or received by you from Drisonline.com for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 25. All documents that were sent to “you”, you or received by you from defendants Mahendra Agraharkar for period 2014 to present date. 4823-8681-8127 v1 2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. Defendant further objects as duplicative. 26. All documents, meeting minutes, notes between “you” and any and all shareholders and partners of NIRP for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 27. All documents that were sent to “you” you or received by you from Hashmet Wali, Wali & Associates, and/or Robin Jacoby for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the acops of the request as not limited in time to the subject matter of this lawsuit. 28. All documents including but not limited to Articles of Organization for all defendant companies in which your name appears in for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 29. All documents including but not limited to all Agreements pertaining to all defendant companies in which your name appears in for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad, Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 30. All documents pertaining directly or indirectly to the defendant companies for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 31. All agreements, contracts, shareholdings, partnership documents, letters of understanding, equity participation, ownership interest, and guarantees by and between you and all partners regarding the defendant companies from inception to date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 4823-8681-8127 vi 2934734-000003 12/04/201732. All documents related to architectural, engineering, site plans, design and drawings pertaining to defendant companies from inception to date. Respo! nse: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 33. All documents related to any statements (signed or otherwise) from any individual regarding the subject matter of this action. Response: As the term "statement" is defined in the Texas Rules of Civil Procedure, none. 34, All documents relied upon by you in answering the Requests for Production propounded to you in this action. Response: In addition to work produce and attorney-client privilege, Defendant objects to this request as beyond the scope of permissible discovery. 35. All documents related to attorney fee agreements entered into by you regarding this lawsuit. Response: Defendant objects to this request as beyond the scope of permissible discovery as not reasonably calculated to lead to admissible evidence. 36. All documents evidencing attorney fee agreements entered into by you regarding the formation of companies with provision to services now being offered by the defendant companies from inception to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 37. All documents, which support and/or provide evidence of each of your alleged denial herein. Response: Defendant objects to this request as vague, ambiguous and undefined. Defendant has no understanding of what denial, if any, this request concerns, 38. All documents, which support and/or provide your interest in each of the defendant companies from 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 39. All documents, showing share certificate(s) you own pertaining to the defendant companies from inception to present date. 4823-8681-8127 v1 2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 40, All tape recordings of any person having knowledge of arvy facts relating to the subject matter of this Lawsuit. Response: Defendant has not tape recordings of any matters pertinent to the subject matter of this lawsuit as Defendant understands it. 41. All photographs, video or moving pictures relating to the subject matter of this Lawsuit. Response: Defendant objects to this request as overbroad. 42. All Witness Statements made in tangible (written or otherwise recorded or memorialized) from by any person relating to the subject matter of this Lawsuit. Response: Defendant objects to this request as duplicative. Subject to the foregoing objection, none 43, All documents reflecting or concerning any agreement you have reached with anyone relating, in whole or in part, to the subject matter of this Lawsuit. Response: Defendant objects to the request as vague, ambiguous and overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 44. All documents which you received from, or took from Plaintiff and which you sent, gave or otherwise provided to any third party. Response: Defendant objects to this request as duplicative. Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 45. All documents which reflect, discuss contain any communications between you and Plaintiff. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 46. All documents which you received from, or took from, any Person that concen Sam Alam. 4823-8681-8127 v1 2934734-000003 12/04/2017Response: Defendant objects to the request as not limited to the Subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 47. — All documents pertaining to your business and financial plans including drafts from inception to date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 48. All documents that were sent to “you” you or received by you from defendants Ajay Choudhry for period 2014 to present date. Response: Defendant objects to the request as not limited to the subject matter of this lawsuit and is, therefore, overbroad. Defendant further objects to the scope of the request as not limited in time to the subject matter of this lawsuit. 10 4823-868 1-8127 vi 2934734-000003 12/04/2017