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Transcript of "IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT ..."
1. IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION ) In re BRIDGESTONE/FIRESTONE, INC. ) ATX, ATX II, AND WILDERNESS TIRES ) Master File No. IP 00-9373-C-B/S ) PRODUCTS LIABILITY ) LITIGATION ) MDL No. 1373 THIS DOCUMENT RELATES TO ALL ) Hon. Sarah Evans Barker ACTIONS ) __________________________________________) FORD MOTOR COMPANY'S OPPOSITION TO BRIDGESTONE/FIRESTONE, INC.'S MOTION TO COMPEL Defendant Ford Motor Company ("Ford"), states as follows in opposition to Bridgestone/Firestone, Inc.'s ("Firestone") Motion To Compel Ford Motor Company To Produce Documents In Response To Firestone's First Set Of Requests For Production Of Documents And Things ("Requests" or "Firestone's Requests"). INTRODUCTION Firestone's Motion to Compel is misplaced and unavailing. As set forth in detail below, Firestone's Requests are in large part grossly overbroad, unduly burdensome, redundant, duplicative of prior requests propounded by other parties, and are not reasonably calculated to lead to the discovery of admissible evidence. Firestone alone has propounded 184 requests on Ford, not including subparts, in addition to the more than 500 requests propounded by Plaintiffs. In response, Ford has, at phenomenal expense and effort and in full compliance with the Federal Rules of Civil Procedure, searched for and produced millions of pages of responsive documents. In Request No. 2, by way of example, Firestone seeks all documents "constituting, embodying, reflecting, analyzing, discussing, transmitting, transcribing, summarizing, or any
way relating to . . . the design and development of the Ford Explorer." 1 Firestone's request lacks any reasonable limitation. It seeks documents relating to the design and development of every feature and component of the Explorer, from the engine and powertrain to the seats, restraints, glazing, sound system, and heating and air conditioning system. Moreover, Firestone does not limit its overbroad requests to the Explorer, or even to Ford sports utility vehicles in general. In Request No. 117, Firestone seeks all documents constituting or relating in any way to "any engineering analysis of any sort regarding vehicle handling, stability, ride or control, or biomechanics during or following a tread/belt separation or other tire failure." Like Request No. 2, Request No. 117 lacks any reasonable limitation. It seeks documents relating to all vehicles of every make, model and vintage, and engineering analyses of any sort relating to any and all tire failures regardless of failure mode, the type of tire, or the manufacturer of the tire. Despite the breadth of Firestone's requests, Ford has made every reasonable effort to identify responsive documents within the scope of the matters at issue in this litigation. Ford has also invited Firestone to meet and confer in order to formulate reasonable and mutually acceptable scopes for many of the Firestone requests at issue in Firestone's motion. See, e.g., Ford's Responses to Requests Nos. 5, 10, 13, 39, 43-45, 47, 49-51, 55-58, 60, 76, 77, 85, 86, 93- 95, 98, 100, 101, 112, 117, 119, 120 (Firestone Memorandum in Support, Tab 3). While the parties conferred on some issues after Ford served its objections to Firestone's discovery on August 6, 2001, many of the particular requests at issue here were not addressed. Moreover, despite Ford's invitation, the parties have not met on these requests at all since Ford filed its substantive responses to Firestone's discovery on September 5, 2001. Contrary to the 1 While Firestone Request No. 2 is not at issue in Firestone's motion, it is indicative of the over breadth of all the requests that follow, and aptly illustrates what Ford had to contend with in responding to the Firestone Requests. 2
requirements of this Court's Case Management Order and Local Rule 37.1, Firestone filed its motion to compel without first meeting with Ford in an effort to narrow the issues in controversy. Firestone's primary complaint concerns Ford's production of documents in an electronic depository accessible via the internet on the forddocs.com website. Ignoring the website's sophisticated search features and the production of documents by category in the depository, Firestone refers to the depository as a "classic data dump" and an "undifferentiated mass of records." Firestone Memorandum in Support, p. 19. Tellingly, despite its complaints, Firestone has requested forddocs.com passwords for several individuals, and apparently is making good use of the system. Firestone seeks to compel responses to 54 document requests and 4 requests for production of things. In each instance, Ford's objections and responses comply fully with the Federal Rules of Civil Procedure. Nevertheless, in light of the Firestone's narrowing of certain requests in its brief, and in an effort to resolve this matter short of court intervention, Ford will voluntarily supplement its initial response by October 19, 2001 and further identify by Bates range specific documents responsive to many of the requests at issue. The Firestone Requests at issue here are overbroad, redundant, unduly burdensome, and seek a wide range of material that is not relevant to this case and not likely to lead to the discovery of admissible evidence. Nevertheless, Ford has responded to the Firestone Requests in good faith and provided Firestone the documents it seeks within the bounds of relevancy. Under any measure, Ford has met its discovery obligations to Firestone, and Firestone's motion should be denied. 3
ARGUMENT I. The Requirements Of Federal Rule Of Civil Procedure 26 Rule 26 requires parties to litigation to make reasonable responses to discovery requests. See, e.g., Fed. R. Civ. P. 26(g) (requiring an attorney to make a reasonable inquiry to ensure that a party has reasonably responded to discovery). Reasonableness, by definition, is case-specific, and turns on the scope of the matters in dispute among the parties, the need for the discovery at issue, the unique circumstances of the case and the parties, and the burden or expense of the proposed discovery. See Tec-Air, Inc. v. Nippondenso Mfg. USA, Inc., No. 91 C 4488, 1994 U.S. Dist. LEXIS 2026 at *26-27 (N.D. Ill. Feb. 23, 1994) ("What ultimately constitutes reasonableness depends on the circumstances of each case."); Poole ex rel. Elliott v. Textron, Inc., 192 F.R.D. 494, 503 (D. Md. 2000) (same); IBP, Inc. v. Mercantile Bank of Topeka, 179 F.R.D. 316, 320 (D. Kan. 1998) ("The interrogatories and responses call for a balance between the need for fair access to material information and the burden of producing it. [Rule 26(b)] authorizes liberal discovery within reasonable bounds determined by judicial discretion."). Under Rule 26(b)(2), the Court may, in response to a motion for a protective order or on its own initiative, "limit discovery if it determines that (1) the discovery sought is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome, or less expensive . . . or (2) the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' resources, the importance of the litigation, and the importance of the proposed discovery in resolving the issues." While Ford has not sought a protective order in response to the Firestone Requests, Ford has interposed objections to Firestone's over broad, duplicative and redundant discovery, and Rule 26(b)(2) is an important guidepost by which to measure the 4
propriety of the Firestone Requests. See Fed. R. Civ. P. 26(b)(2) Advisory Committee Notes (2001) (emphasizing the desirability of courts more vigorously applying the Rule 26(b)(2) cost- benefit factors when determining allowable discovery). It is Firestone's burden to prove that the documents it seeks are relevant. Salvatorie Studios, Int'l. v. Mako's, Inc., No. 01 Civ. 4430 (BSF)(DF), 2001 U.S. Dist. LEXIS 11729 (S.D.N.Y. Aug. 13, 2001) (citation omitted). Under Rule 26(b)(1), Ford can withhold irrelevant documents from production. In re: Vitamin Antitrust Litig., Misc. No. 99-197 (TFH), MDL No. 1285, 2001 U.S. Dist. LEXIS 11536, at *37 (D.D.C. Apr. 23, 2001) (citations omitted). "While the Supreme Court has mandated [under the former Rule] that Fed. R. Civ. P. 26(b)(1) be construed broadly, courts should not allow parties to "roam in the shadow zones of relevancy and to explore matter which does not presently appear germane on the theory that it might conceivably become so." Spina v. Our Lady of Mercy Med. Ctr., No. 97 CIV 4661 (RCC), 2001 U.S. Dist. LEXIS 7338 (S.D.N.Y. June 6, 2001) (citations omitted). As noted by Firestone, effective December 1, 2000, Rule 26(b) (1) was amended to limit the scope of discovery to matters related to "the claim or defense of any party." Firestone Memorandum in Support, p. 7, n. 5. Contrary to Firestone's suggestion, however, the purpose and effect of the amendment was to narrow the scope of discovery "in some meaningful way" and to involve the court more actively "in regulating the breadth of sweeping or contentious discovery." Fed. R. Civ. P. 26(b)(1) Advisory Committee Notes; Surles v. Air France, No. 00 Civ. 5004 (RMB)(FM), 2001 U.S. Dist. LEXIS 15315, at *4 n.3 (S.D.N.Y. Sept. 27, 2001). Applying the clear dictates of Rule 26, Firestone's motion should be denied. 5
II. The Firestone Requests Are Overbroad, Unduly Burdensome And Not Reasonably Calculated To Lead To The Discovery Of Admissible Evidence Most of the document requests at issue in Firestone's motion are overbroad and seek documents that are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Many of the requests at issue seek documents relating to the design, development and performance of all light trucks and sport utility vehicles produced since 1980, regardless of manufacturer. See, e.g., Request Nos. 32, 33, 34, 42, 44, 45, 47, 49, 50, 107, 109, 111, 117. Others seek production of documents relating to all tire failures, regardless of the type or size of tire, the identity of the tire manufacturer, or the alleged failure mode. See, e.g., Request Nos. 44, 45, 47, 49, 50, 105, 106, 107, 109, 111, 112, 114, 115, 117, 120, 122. Nearly all the requests, in whole or in part, seek the production of documents and information wholly unrelated to the tire performance and vehicle handling issues raised in this litigation. In Request No. 50, for example, Firestone seeks all documents constituting or relating in any way to "any communication or meeting between Ford and any person regarding (1) the failure of any tire on any SUV or LT produced since 1980 or (2) the stability, control, handling or emergency maneuver characteristics of any SUV or LT produced since 1980." Request No. 50 seeks documents relating to any and all handling characteristics on all sports utility vehicles and pickup trucks, regardless of manufacturer, produced since 1980, as well as documents relating to the failure of any tire, without regard to the manufacturer of the tire, the size of the tire, the type of tire, or the failure mode. Read literally, Request No. 50 would require Ford to produce documentation of a hypothetical customer complaint made in 1980 that the Goodyear snow tires on her new Ford F- 150 pickup truck repeatedly went flat. Read literally, it would further require Ford to produce 6
documentation of a hypothetical inquiry from NHTSA concerning the handling characteristics of compact pickup trucks when towing campers. Ford, and presumably Firestone, would agree that this is not what Firestone actually intended. The problem, however, is defining an appropriate limitation under these circumstances on the scope of Firestone's Requests. Ford cannot be required to guess Firestone's desires and thereby risk either producing too much information – only to be accused of "dumping" – or produce too little – only to be accused of withholding important information. As noted by Firestone, "evidence regarding other incidents of the same type, or involving the same product, are properly discoverable" under Rule 26. Firestone Memorandum in Support, p. 10 (citing Fed. R. Civ. P. 26(b)(1) Advisory Committee Note; and Anderson v. Hale, No. 00C 2021, 2001 WL 64113 at * 2 (N.D.Ill. June 1, 2001)). Ford agrees. Discovery in automotive product liability actions is routinely limited in scope to substantially similar vehicles and accident circumstances. In Piacenti v. General Motors Corp., 173 F.R.D. 221, 225 (N.D. Ill. 1997), an action involving a 1991 Geo Tracker, the court upheld General Motors' objections to plaintiffs' discovery requests regarding the Suzuki Samurai on the ground that the two vehicle models are dissimilar and that the plaintiffs' discovery requests were thus unduly burdensome and sought information that was neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. The court noted that "[t]he legal tenet that relevancy in the discovery context is broader than in the context of admissibility should not be misapplied so as to allow fishing expeditions in discovery." Id. at 224 (citing Hofer v. Mack Trucks, Inc., 981 F.2d 377, 380 (8th Cir. 1992)). "Allowing discovery of models that are not substantially similar to the model at issue is truly the equivalent of comparing apples and oranges where there are 7
differences between the other models and the model at issue." Id. at 225; see also Uitts v. General Motors Corp., 62 F.R.D. 560, 562 (E.D. Pa. 1974) (in a handling case involving a Chevrolet Blazer, court limited discovery to the Blazer model at issue and declined to order production of information on dissimilar vehicles with dissimilar parts). 2 This case involves tread/belt separation failures of Firestone P235/75R15 ATX and Wilderness AT tires on Ford Explorers. Ford agrees that the performance of the same or substantially similar tires on other sports utility vehicles and the performance of other manufacturers' tires on the Explorer may be relevant to show that it was the design and manufacture of the subject Firestone ATX and AT tires, as opposed to the Explorer, that led to the failure of the Firestone tires. Ford has produced responsive documents pertaining to this issue. This does not open the door, however, to unfettered discovery regarding the handling characteristics of all sports utility vehicles and light trucks produced since 1980 or the performance of all tires of all types installed on such vehicles. Firestone's requests are grossly overbroad and improper. Tellingly, Firestone has withdrawn its request for documents relating to the Ford Ranger. Firestone Memorandum in Support, p. 1. Presumably, by extension, Firestone is withdrawing its requests for documents relating to other Ford pickup trucks, vans, and other vehicles that might 2 Although Uitts was distinguished by Swain v. General Motors Corp., 81 F.R.D. 698 (W.D. Pa. 1979), federal courts since Swain have not hesitated to cite Uitts with approval when limiting discovery in products liability cases. See, e.g., Hofer, 981 F.2d at 381 (citing Uitts and denying discovery on other truck models so "sufficiently dissimilar in design [from the model being litigated] that a burdensome production of documents regarding the design minutiae of those earlier models would not have yielded information which would have supported [plaintiff's] claim that the model . . . truck cab was defective"); Fine v. Facet Aerospace Prods. Co., 133 F.R.D. 439, 442 (S.D.N.Y. 1990) (citing Uitts for the proposition that "where there has been no suggestion that other models share pertinent characteristics with the products at issue, discovery relating to those models will be disallowed" and denying discovery because plaintiff failed to make threshold showing that the other designs were relevant); In re: Richardson-Merrell, Inc. "Bendectin" Prods. Liab. Litig., 624 F. Supp. 1212, 1241 (S.D. Ohio 1985) (relying on Uitts to refuse discovery because "not confining discovery to Bendectin and its components alone or in combination with other components would have necessarily opened all of defendant's drugs to discovery – a result that would be truly oppressive and would thwart any attempt at a just, speedy, or inexpensive determination of the action"). 8
be classified as light trucks. 3 Firestone improperly insists, however, on obtaining all documents relating to the Ford Bronco II. Firestone Memorandum in Support, p. 8. The Ford Bronco II was introduced in 1984 and has been out of production since 1990. The Explorer was first introduced in 1990. The design and development of the Bronco II predates the design and the development of the Explorer by several years, and the Bronco II program is wholly irrelevant to the issues raised in this litigation. While there may be several isolated instances where a Ford employee referred to the Explorer as an "updated" version of the Bronco II, see Firestone Memorandum in Support at 8, n. 6, the Bronco II and the Explorer are different vehicles that were separately developed with different designs and features. Notably, Firestone has been involved as Ford's co-defendant in litigation involving the Bronco II. Firestone is familiar with the design and performance of the Bronco II. Moreover, Ford has produced in this case a voluminous set of indexed documents relating to the design, development and performance of the Bronco II. Ford has fully met its discovery obligations with respect to the Bronco II. 4 As yet another example of the overbreadth of Firestone's discovery, Request No. 8, which incorporates Request Nos. 6 and 7, including 23 subparts in Request No. 6, seeks all documents referring to or relating in any way to The identity, professional background, opinions, bases for opinions, reports, communications, and testimony of any person who served as or was named as an expert or consultant, or who testified regarding vehicle stability, ride, handling, rollover, loss of control, or emergency maneuvering in or concerning any complaint/claim/lawsuit or customer contact [involving any allegation, contention or assertion that any Ford Explorer went out of control wholly or partly because of some inappropriate or 3 Firestone declines to define "light truck." As defined by Ford, the light truck category includes the Ford F-series, Ranger, Bronco, Bronco II, Aerostar, E-Series, Explorer, Expedition, and Windstar. 4 See Ford's responses to Request Nos. 17, 18, 24, and 25 relating to the Bronco II. 9
defective aspect of the vehicle or that any Ford Explorer is defective in any manner because of its (a) actual or alleged propensity to rollover, (b) actual or alleged lack of understeer, (c) actual or alleged lack of linear control . . . (d) handling characteristics, (e) stability characteristics, . . (h) steering characteristics, (i) turning characteristics, . . . (r) wheels or any element thereof, (s) suspension system or any element thereof . . . (v) anti-lock braking [and] (w) shielding or protection against damage from objects, including parts of tires, striking any part of the underside of the vehicle.] Firestone's request, read literally, seeks extensive documentation relating to any Ford expert or non-testifying consultant, any plaintiff's expert or non-testifying consultant, any co- defendant expert or non-testifying consultant, any Ford, Firestone or other co-defendant employee, any plaintiff, or any other lay witness who gave any opinion testimony about vehicle stability, ride, handling, and other issues in any case involving the Explorer from 1990 to the present. Such a request is patently overbroad and seeks information about non-testifying consultants that is protected from disclosure when, as here, Firestone has made no attempt to meet the "heavy burden" 5 of demonstrating "exceptional circumstances" under Fed. R. Civ. P. 26(b)(4)(B). 6 Braun v. Lorillard Inc., 84 F.3d 230, 235-36 (7th Cir.), cert. denied, 519 U.S. 992 (1996); Ager v. Jane C. Stormont Hosp. and Training Sch. for Nurses, 622 F.2d 496, 502 (10th Cir. 1980) (noting that this rule "was largely developed around the doctrine of unfairness 5 Kiser v. General Motors Corp., Civil Action No: 98-3669 Section: "L"(3), 2000 U.S. Dist. LEXIS 10479, at *9 (E.D. La. July 19, 2000); State Auto Ins. Cos. v. Briley, 140 F.R.D. 394, 397 (E.D. Mo. 1992) (citing Kuster v. Harner, 109 F.R.D. 372, 375 (D. Minn. 1986)). 6 See also Pickett v. IBP, Inc., Civil No. 96-A-1103-N, 2000 U.S. Dist. LEXIS 19500, at *9-*10 (M.D. Ala. Oct. 16, 2000) (noting four reasons why information from non-testifying consultants should be protected – "(1) an 'important interest in allowing counsel to obtain the expert advice they need in order properly to evaluate and present their clients' position without fear that every consultation with an expert may yield grist for the adversary's mill,' . . . (2) unfairness of allowing an opposing party to benefit from a party's effort and expense incurred in preparing its case; (3) fear of restraint on the willingness of experts to serve as consultants if their testimony could be compelled; and (4) the substantial risk of 'explosive' prejudice stemming from the fact of the prior retention of an expert by the opposing party") (citation omitted). As discussed supra , the 2000 Amendment narrowing the scope of discovery under Rule 26(b)(1) reinforces these critical substantive protections. 10
designed to prevent a party from building his own case by means of his opponent's financial resources, superior diligence and more aggressive preparation"). Firestone's Request No. 35 seeks all documents constituting or relating in any way to "any subjective test and the results thereof for the Ford Explorer, Ford Bronco II and/or Ford Ranger." On its face, this request calls for any and all documents relating to any subjective analysis of the Explorer, and would include such matters as ride comfort and roominess, the accessibility and ease of use of the dashboard controls, and interior noise levels. In its brief, Firestone recasts this request to call for "documentation of a test drivers' subjective reaction to driving one of these vehicles." Firestone Memorandum in Support, p. 14, n.10. While this somewhat narrows the request, the request even as redrawn still calls for documents having nothing to do with handling and stability issues. Obviously, Ford should not have to learn of Firestone's actual intent through a motion to compel. Firestone should properly craft its requests in the first instance to seek the documents it wants rather than leaving Ford to divine Firestone's intent. If there is to be a narrowing of Firestone 's requests, it should occur at the meet and confer stage, and because of a motion to compel. Ford stands on its objections to Firestone's requests to the extent that these requests are overbroad, unduly burdensome, and seek documents that are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Ford is prepared to defend its objections to this Court or to meet and confer with Firestone in an effort to narrow the issues in controversy concerning the breadth of Firestone's requests. In either event, Firestone's motion should be denied. 11
III. Firestone 's Requests Are Duplicative Of Other Discovery Previously Served On Ford Most of the Firestone Requests, served on Ford on or about July 6, 2001, are duplicative of requests served on Ford on or about June 13, 2001 in the consolidated Explorer/Firestone state court litigation pending in Texas. See Texas Plaintiffs' Supplemental Request For Production Of Documents ("Texas Plaintiffs' Requests"), attached as Exhibit 1. Firestone is a party to the Texas litigation. Although the Texas Plaintiffs' Requests were served on all counsel of record in that proceeding, Firestone claims never to have seen the requests. Firestone Memorandum in Support, pp. 3, n. 2, 19. However, as demonstrated by a quick comparison of Firestone Request Nos. 1-6 to Texas Plaintiffs' Request Nos. 139-144, the order and phraseology of the requests are nearly identical. Texas Plaintiffs' Request No. 139 Firestone Request No. 1 Documentation "of the creation of All documents relating to "the the initial idea and plan for initial idea and plan for developing developing the Ford vehicles the Ford Explorer and the goals originally denominated as UN46's sought to be achieved by its and later denominated as Ford development." Explorers, and the goals sought to be achieved in such development." Texas Plaintiffs' Request No. 140 Firestone Request Nos. 2 and 3 Documentation "of the design, All documents relating to "the development, and testing of Ford design or development of the Ford Explorers as related to (1) Explorer . . .[and] any testing, prevention, or reduction in the analysis or review of the Ford likelihood, or failure of any tire, (2) Explorer with respect to stability, prevention of loss of control or ride, handling, rollover, loss of drivability following a tire failure control, or emergency maneuver or disablement while the vehicle is characteristics." in motion, (3) directional stability, static or dynamic resistance to rollover, and/or (5) (sic) vehicle handling and control . . . ." 12
Texas Plaintiffs' Request No. 141 Firestone Request No. 4 Documentation of "the contribution Documents relating to "the effect or non-contribution to any or non-effect of any vehicle part occurrence of loss of control of [or] component . . . on the Ford Explorers by (1) the inflation stability, ride, handling, rollover, level of the vehicle's tires, (2) the loss of control or emergency size of the vehicle's tires, (3) the maneuver characteristics of the rolling resistance of the tires or any Ford Explorer, including, but not permutation or combination limited to: (a) the size, inflation thereof, (4) the amount of surface level, or rolling resistance of the friction of the roadway on which vehicle's tires, or any combination the vehicle is proceeding, (5) the or permutation thereof, (b) the weight of the vehicle, (6) the amount of surface friction of the configuration or distribution of the roadway on which the vehicle is weight of the vehicle . . . [and 23 proceeding, (c) the weight of the other factors]." vehicle, (d) the configuration or distribution of the weight of the vehicle . . . [and 18 other factors]." Texas Plaintiffs' Request No. 142 Firestone Request No. 5 Documentation of "any occurrence, Documents relating to "any actual experienced or alleged to have been or alleged occurrence of any experienced at any time by anyone, person losing control of, or rolling of loss of control or drivability of over in, a Ford Explorer." Ford Explorers." Texas Plaintiffs' Request No. 143 Firestone Request No. 6 Documentation of Documents relating to "any "complaints/claims/lawsuits complaint/claim/lawsuit or other involving allegations, contentions, customer contact involving any assertions, or facts that any Ford allegation, contention or assertion Explorer had or has inappropriate that any Ford Explorer is defective or defective (1) propensity to roll in any manner because of its: (a) over or pitch over, (2) handling actual or alleged propensity to characteristics, (3) stability rollover, . . . (c) actual or alleged characteristics, (4) control lack of linear control . . . (d) characteristics . . .[ and 17 other handling characteristics, (e) enumerated items ]." stability characteristics . . . [and 19 other enumerated items ]." 13
The suggestion that Firestone drafted its requests without any reference to the Texas Plaintiffs' Requests (or some other prior set of requests on which both drafters relied) is not credible. 7 As set forth in Ford's responses, certain of the Firestone Requests are also duplicative of requests propounded by the MDL Plaintiffs. Firestone argues that Firestone Request No. 45, among the requests at issue, is not duplicative of MDP Plaintiffs' Request Nos. 72, 239, and 248. Firestone Memorandum in Support, p. 17. To a degree, Firestone is correct. Firestone Request No. 45 seeks documents relating, without limitation, to all tires on all sports utility vehicles and light trucks produced since 1980. The MDL plaintiffs' requests on the other hand are more properly limited to Firestone ATX, ATXII and Wilderness AT tires. In any event, despite the unnecessary burden resulting from the duplicative Firestone Requests, Ford has nowhere refused to respond to the Requests on the grounds they are duplicative. Indeed, the only direct mention of the Texas Plaintiffs' Requests in Ford's discovery response to Firestone is in its General Objections. Now that this matter is before the Court, however, it is appropriate for the Court to place limits on Firestone's duplicative discovery and require Firestone to acquire the documents it seeks in a manner that does impose undue burden. To the extent Firestone already has documents in its possession from other sources, including documents produced by Ford in the Texas state court litigation, Ford should not have to reproduce those documents here. 8 Fed. R. Civ. P. 26(b)(2)(i) (stating that discovery 7 Other Firestone Requests duplicative or substantially similar to the Texas Plaintiffs' Requests are Request Nos. 7, 10, 12, 15-21, 24, 26, 28-42, 44-50, 55-95, 97-132, and Request Nos. I, II, and IV-VI. 8 Firestone's citation to Prins v. International Tel. and Tel. Corp., 757 F. Supp. 87 (D.D.C. 1991); Bonilla v. Trebol Motors Corp., Civil No. 92-1795 (JP), 1997 WL 178844 (D.P.R. Mar. 27, 1997), rev'd on other grounds sub nom. Bonilla v. Volvo Car Corp., 150 F.3d 88 (1st Cir. 1998); Burton Mech. Contractors, Inc. v. Foreman, 148 F.R.D. 230 (N.D. Ind. 1992); and Wilk v. American Med. Ass'n, 635 F.2d 1295 (1980), does not change this conclusion. In Prins, because plaintiff had supplemented his discovery responses, one defendant was allowed additional discovery to develop its own theories despite co-defendant's agreement to produce documents it might use at trial. Prins, 757 F. Supp. at 95. In Bonilla , production of documents already provided by another defendant was necessary because plaintiffs had to correlate documents between the two defendants to prove their case. Bonilla , 1997 WL 178844, at 14
"shall be limited . . . if . . . [it] is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome, or less expensive"); Higgins v. Higgins, Case No. 95 CV 4465, 1997 U.S. Dist. LEXIS 2305, at *8-*9 (N.D. Ill. Feb. 20, 1997) (denying inter alia discovery of materials that "have been produced or answered by way of affidavit . . . [and that] could be more easily obtained from other sources"); Maze v. Hargett, No. 4:94CV211-D-A, 1996 U.S. Dist. LEXIS 22375, at *6-*7 (N.D. Miss. Jan. 12, 1996) (denying motion to compel when materials were already in movant's possession). IV. The Firestone Requests Are Confusing And Internally Redundant Firestone takes pains to point out several drafting mistakes in Ford's objections and responses, perhaps to divert the Court's attention from the substance of Firestone's requests. The Firestone Requests also contain drafting mistakes, and even a cursory review of the requests illustrates that they are over broad, duplicative and redundant, confounding any effort by Ford to provide neat and orderly responses. By way of example, Request No. 3 seeks documents constituting, referring to or relating in any way to "any testing, analysis, or review of the Ford Explorer with respect to stability, ride, handling, rollover, loss of control, or emergency maneuver characteristics." Presumably any document referring to or analyzing the effect of the Explorer's tires, wheels, suspension, geometry, weight, and steering on its stability and handling would be responsive to this request, and that is how it was understood by Ford. Yet in Request No. 4, Firestone seeks documents constituting, referring to or relating in any way to *10. Burton is distinguishable because the other party whose documents would potentially be produced had been evading discovery – there is no evidence that this has occurred here. Burton, 148 F.R.D. at 234. Finally, the United States Court of Appeals for the Seventh Circuit in Wilk, like the MDL Panel "in litigation of this magnitude," was "impressed with the wastefulness of requiring the State of New York to duplicate discovery already made." Wilk, 635 F.2d at 1299. It resolved the discovery dispute by modifying the protective order already in place. Id. 15
the effect or non-effect of any vehicle part, component, system [or] subsystem . . . on the stability, ride, handling, rollover, loss of control or emergency maneuver characteristics of the Ford Explorer, including [among 22 enumerated items] (a) the size, inflation level, or rolling resistance of the vehicle's tires, or any combination or permutation thereof, . . . (c) the weight of the vehicle, . . . (g) the wheelbase or track width of the vehicle, . . . (i) the suspension system, or and [sic] element thereof, on the vehicle, (j) the steering system, or any element thereof, on the vehicle, [and] (t) the steering system, or any element thereof, on the vehicle. Ignoring Firestone's own drafting mistakes (e.g., repeating its reference to the steering system), it is difficult for Ford to discern what documents would be covered by Request No. 4 that are not covered by Request No. 3. In the same vein, if "effect" is given its usual and customary meaning, it is difficult for Ford to discern what Firestone intended by including the term "non-effect" in its request. In Requests Nos. 42, 43, 44, 51, 55, 56, 57, 58, 76, and 86, Firestone seeks documents regarding Ford's representations to NHTSA and Congress concerning the Firestone tire controversy, including in particular Ford's March 28, 2001 submission to NHTSA, and all documents "regarding these representations, as well as documents regarding the meetings and presentations at which these representations were made." Firestone Memorandum in Support at 11. Of these requests, Request No. 42 seeks documents constituting or relating in any way to "any communication between Ford and any state or federal legislative body or agency . . . including but not limited to NHTSA and the Department of Transportation . . . ." This request seemingly would cover documents relating to Ford's formal submissions to NHTSA, including its March 28, 2001 submission. Yet in Request No. 55, Firestone separately seeks all documents relating to "Ford's March 28, 2001 NHTSA Submission, including, but not limited to its creation, development, and presentation as well as the testing reported and representations made 16
in that submission." Request No. 76 further requests all documents relating to the assertion in Ford's March 28, 2001 NHTSA Submission that "Explorers have a margin of safety 'as designed' to accommodate, to a reasonable level, component failures including tread separations," and Request No. 86 requests all documents relating to the assertion in Ford's March 28, 2001 NHTSA Submission that "Absent unique factors, an Explorer will not be forced out of control by vehicle factors before, at, or after tread separation." As conceded by Firestone in referencing these requests as a group in its brief, these requests are redundant. In the same vein, while Request No. 42 also seemingly covers all of Ford's presentations to Congress concerning the Firestone tire controversy, Firestone separately requests all documents relating to "the preparation of Ford officials for testimony before Congress on September 6, 2000, September 12, 2000 and/or June 19, 2001." See Request No. 43. Firestone has also propounded a new set of 44 requests all relating to the June 19, 2001 testimony of Ford's President and CEO, Jacques Nasser, before Congress. See Bridgestone/Firestone, Inc.'s Requests For Expedited Production By Ford Motor Company Of Documents Relating To The June 19, 2001 Testimony Of Jacques Nasser Before Congress, attached as Exhibit 2. While it may be appropriate to occasionally recast a document request to ensure a complete response, Firestone's repeated redundant requests are unduly burdensome and improper. As with the duplicative Firestone Requests, Ford has nowhere refused to respond to the Requests on the grounds they are redundant. Ford has properly, when responding to redundant Firestone requests, incorporated its responses to other Firestone requests seeking the very same documents. See 7 James Wm. Moore et al., Moore's Federal Practice § 33.103 (3d ed. 1997) (noting that it is appropriate when responding to interrogatories "to refer to answers of other interrogatories or other discovery in order to avoid unnecessary repetition . . . ."); Loyd v. Rubin, 17
Civil Action No. 3:96-CV-0010-D, 1999 U.S. Dist. LEXIS 19436, at *10 (N.D. Tex. Dec. 15, 1999) (denying motion to compel in part because answer cited other interrogatory responses and was deemed complete); Tucker v. Janota, No. 75 C 2931, 1978 U.S. Dist. LEXIS 14603, at *5 (N.D. Ill. Nov. 1, 1978) (denying sanctions because it was proper "[i]n light of the extensive document production . . . requested" to adopt previous responses when requests sought the same information). V. Ford Has Properly Responded To The Firestone Requests By Producing Documents In Electronic Format, By Designating Bates Ranges Of Responsive Documents Available To Firestone In Ford's Electronic Depository, And By Incorporating Prior Responses To Redundant Requests Firestone complains that Ford has failed to produce any responsive documents, with two minor exceptions, other than what it has compiled and placed in its electronic depository. Firestone Memorandum in Support, p. 6. While the electronic depository is the primary means by which Ford has produced documents, Ford has produced numerous documents to plaintiffs and Firestone in hard copy, including video tapes, schematic drawings, database runs, and witness books. Ford's production of documents via an electronic depository is proper and appropriate. See e.g., In re Diet Drugs (Phentermine, Fenfluramine, Dexfenfluramine) Prods. Liab. Litig., MDL Docket No. 1203, Civil Action No. 99-20593, 2000 U.S. LEXIS 12275 (E.D. Pa. Aug. 28, 2000) (settlement agreement and related documents made available online after production of over 6,000,000 pages of documents at a document depository). 935 F. Supp. 1452 (D. Colo. 1996). It is clear that voluntarily providing documents in a searchable database complies with Rule 1's overriding purpose of securing "the just, speedy, and inexpensive determination of every action." Wegner by Wegner v. Cliff Viesmman, Inc., 153 F.R.D. 154, 157 (N.D. Iowa 18
1994) (observing that "the objectives of the discovery rules must be kept in mind so that a just and speedy determination of cases can be obtained"); Manville Sales Corp. v. Paramount Sys., Inc., Civil Action No. 86-4157, 1987 U.S. Dist. LEXIS 11566, at *8 (E.D. Pa. Dec. 16, 1987) (same); Snead v. American Export-Isbrandtsen Lines, Inc., 59 F.R.D. 148, 151 (E.D. Pa. 1973) (same). As the Court is aware, forddocs.com is not an "undifferentiated mass" of records On the contrary, this method of production has been acceptable to the NHTSA, the U.S. Congress, Texas CMO, California CMO and many individual cases. The reason for forddocs.com's acceptance is its functionality. Assuming Ford had produced the current 3.9 million pages of documents to plaintiffs or Firestone as kept in the normal course of business (or in a manner similar to Firestone's dump), the documents would then have to be imaged, coded, reviewed, and scanned by the plaintiffs and Firestone. Because of the unique circumstances of this case, Ford has done all of these tasks and more. Ford has provided drop-down menus allowing users to search within previous searches conducted for other litigation, or develop their own search methods using the industry standard search engine, Alta Vista, and to produce the materials automatically by either printing on their desktop or in bulk printing by paper or CD. Assuming, then, there was no benefit to be gained by all of the functionality of the search engine or website, it would still allow for a simple paper production of all documents should Firestone wish to return to a pre-computerized method of discovery. No method of production is perfect, particularly in a situation where Ford is being called upon by Firestone and the other parties to produce millions of pages of documents. As set forth above, Rule 26 requires Ford to undergo a reasonable effort to locate and produce documents responsive to Firestone's requests. The fact that one document may not turn up in a search on 19
forddocs.com is not an indictment of the whole system. Indeed, it is likely that any production of this magnitude, whether made in hard copy or electronically, some documents will be inadvertently misplaced despite the best intentions and most conscientious efforts of all involved. While Firestone has quoted from the Court's March 15, 2001 Order concerning potential shortcomings in forddocs.com, Firestone has failed to support any claim that Firestone has been unable to locate the documents it needs to defend its interests in this case. In its March 15, 2001 Order Regarding Document Production, the Court commended Ford's efforts in creating an electronic document repository. Recognizing the plaintiffs' relative lack of knowledge of Ford's documents, however, the Court required Ford to respond to plaintiffs' requests by identifying documents by Bates number such that the documents can be obtained from the depository without using the website's search feature. As stated in the Order, the Court was concerned about the plaintiffs' potential lack of knowledge of common engineering abbreviations and code words and their lack of familiarity with Ford's organizational structure and how individual documents, authors or recipients are related. These concerns do not apply to Firestone. Firestone and Ford had a close working relationship for since 1903 and until this year, Firestone was the primary supplier of OEM tires for Ford vehicles. Firestone is familiar with the acronyms, codes, abbreviations, and buzzwords in the tire and automotive industries, and has routinely interacted with the Ford engineers and departments responsible for tire selection and acquisition. Firestone has been Ford's co-defendant in a number of rollover and tire failure cases involving a variety of Ford vehicles, and presumably is intimately familiar with the Ford documents produced in those cases, as well as the testimony of Ford's engineers and testifying experts. Firestone has also presumably retained numerous experts and consultants in this 20
litigation who are familiar to varying degrees with Ford's documents and the inner workings of Ford vehicle design programs. Firestone is a sophisticated party with substantial resources. Firestone is fully capable of identifying and locating any document it may need from the Ford electronic depository. Firestone knows precisely what documents it is looking for, while Ford can only attempt to divine Firestone's true target from its vague and overbroad discovery requests. As such, it is demonstrably less burdensome for Firestone to search for and locate responsive documents or categories of documents than it is for Ford. This Court has a general duty to minimize discovery burdens in complex litigation and should require Firestone here to incur the burden of reviewing Ford's documents in the electronic depository when preparing its own claims or defenses rather than require Ford to cull out select documents. See Societe Nationale Industrielle Aerospatiale v. United States Dist. Court for the S. Dist. of Iowa, 482 U.S. 522, 546 (1987) ("Judicial supervision of discovery should always seek to minimize its costs and inconvenience and to prevent improper uses of discovery requests."); Wilson v. Wilson, No. 89 C 9620, 1991 U.S. Dist. LEXIS 10992, at *7 (N.D. Ill. Aug. 2, 1991) (noting that district courts generally have the "authority to regulate discovery in such a way as to minimize the unnecessary burdens and disruption potentially caused by expansive discovery"). Nevertheless, Ford has identified responsive documents by Bates number in those instances where it has been able to discern the target of Firestone's requests. In light of Firestone's narrowing of certain requests in its brief, Ford has reviewed each of the requests at issue and will serve Firestone with supplemental responses by October 19, 2001, responding in most cases with a Bates range of responsive documents. Where Firestone's requests are 21
redundant or duplicative, Ford has incorporated its responses to the prior requests. Ford's responses are proper and appropriate. VI. Firestone Seeks To Hold Ford To A More Demanding Standard Than It Is Willing To Abide By Itself Firestone's arguments are largely undercut by the fact that it has, in numerous ways, been far less responsive to Ford's discovery requests than Ford has been to Firestone's requests. This calls into serious question the sincerity of Firestone's complaints with Ford's responses. It also suggests that Firestone is unwilling to abide by the same standards that it demands of Ford. This Court should not condone Firestone's double standard. Pending the outcome of meet and confer negotiations, Ford may soon be filing its own motion to compel responses by Firestone to a limited number of Ford's document requests. In the meantime, it is worth noting a few examples of deficiencies in Firestone's responses that are more egregious than any of Ford's own. First, Firestone objects to the fact that in Ford's responses, Ford refers Firestone to documents located on its website, www.forddocs.com. As the Court is aware, Ford has expended considerable resources to create a website containing millions of pages of documents. The documents on Ford's website are indexed and word searchable. Nonetheless, Firestone complains that it lacks the sophistication to perform searches on the website for documents in which it has an interest, and suggests that Ford should be required to search for and identify by Bates range, documents responsive to its vague and overbroad requests. Though Ford has objected to the scope of Firestone's requests, and though its website provides capabilities far beyond the limited box-by-box index that Firestone has provided for its document production, Ford is voluntarily undertaking to search for documents responsive to many of Firestone's requests, and to create drop-down menus identifying responsive documents by Bates range. 22
Firestone has been far less responsive. Only two of Firestone's responses to Ford's discovery requests identify specific documents – and even those responses do not identify the documents by Bates range. See Bridgestone/Firestone, Inc.'s Response to Defendant Ford Motor Company's First Request for Production, 29, 33, attached as Exhibit 3 ("Firestone Responses"). In every other instance Firestone responds to Ford's requests by offering to "mak[e] the contents of [its] repository available to counsel for Ford." Firestone Responses, p. 3. 9 Firestone's "repository" consists of a warehouse of boxes. Ford has no way of identifying what documents might or might not be responsive other than by relying on an "index" that Firestone does not even claim fully describes the contents of each document. Unlike Ford, Firestone has not undertaken to perform a single search of its repository to locate responsive documents. Firestone's complaints that Ford's responses do not satisfy its obligations under the Federal Rules of Civil Procedure lacks all credibility, given that Ford's website offers Firestone greater search capacity than Firestone's index, and that Ford has voluntarily agreed to provide drop- down menus identifying by Bates range documents responsive to many of Firestone's requests, while Firestone has undertaken no such effort. Second, as noted above, Firestone complains that Ford has not produced documents relating to tires and vehicles wholly different from those at issue in this litigation. Nonetheless, Firestone refuses to produce documents relating to similar tires. For example, in response to a request relating to claims for any P-metric or LT-metric tires manufactured by Firestone, Firestone objects that the request "is not limited to the facts and circumstances of the subject 9 Firestone states that it will provide counsel for Ford copies of the documents in its repository "as provided in the Joint Stipulation on Document Depository Protocol." (Firestone Responses, p. 3.) Ford believes that Firestone is referring to a stipulation it entered into with plaintiffs' counsel regarding Firestone's responses to plaintiffs' document requests. See Order Regarding Firestone's Document Production, March 16, 2001. Ford never entered into any such stipulation with Firestone, and does not agree to be bound by the terms of any stipulation that purports to hold Firestone to a lower standard of responsiveness. 23
accidents." Firestone Responses, No. 31. It is unreasonable for Firestone to ask this Court to compel Ford to produce documents relating to dissimilar vehicles and tires, while Firestone itself refuses to produce documents relating to similar tires. Third, Firestone objects to Ford's refusal to produce confidential documents obtained from third party tire suppliers. Firestone Memorandum in Support, pp. 3, 25. Firestone argues that any concerns regarding proprietary information are already addressed in the Court's March 7, 2001 Confidentiality Order. 10 Nonetheless, while Firestone argues that the Confidentiality Order is sufficient to protect the concerns of third parties, Firestone categorically refuses to produce its own purportedly confidential information under the terms of the Confidentiality Order. See, e.g., Firestone Responses, Nos. 4 and 5. Fourth, Firestone asks the Court to compel Ford to produce documents relating to Ford's alleged retention of former Department of Transportation employees who might have assisted Ford in relation dealing with NHTSA, Congress or any other governmental body regarding tires failures or the Ford Explorer or Bronco II. Firestone Memorandum in Support, p. 11-12. At the same time, Firestone categorically refuses to produce any documents in response to Ford's request for all document "relating to Firestone's consultations or communications with legislative affairs advisors or firms" concerning Firestone's recall, Ford's service action or Ford Explorers in general, on the grounds that such information is both irrelevant and privileged. Firestone Responses, Nos. 10-11. Firestone offers no rationale as to why its communications with legislative affairs advisors are irrelevant and privileged, while similar communications by Ford are supposedly highly relevant and non-privileged. 10 As Firestone as well aware, the Court currently has before it a motion by one of Ford's tire suppliers, Goodyear, addressing confidentiality concerns relating to its proprietary information. 24
Finally, Firestone points to a number of typographical errors in Ford's responses, apparently to suggest that Ford's responses are somehow substantively deficient. Memorandum in Support, p. 2. By that standard, Firestone's own responses are deficient, because they contain similar errors. For example, in response to Ford's Request No. 34, Firestone objects that "Firestone is not apprised of Ford's definition of 'considered' or [']otherwise used' as used in this request." Yet Request 34 does not contain either one of these terms. Firestone's objection is nonsensical. As another example, Firestone's response to Ford's Request No. 23 contains the following incomplete phrase: "Without waiving these objections, Firestone states that documents contained in the document repository as described in the Introductory Statement ¶¶ 2 and 3 above." Ford has no way of knowing what Firestone means by this cryptic response. In sum, not only are Firestone's objections to Ford's responses generally ill founded, but Firestone also relies on a double standard. If, as Firestone argues, Ford's responses do not satisfy its obligations under the Federal Rules of Civil Procedure, then it follows that Firestone's responses, which are significantly less responsive than Ford's, are doubly deficient. VII. Confidential And Proprietary Documents From Firestone's Competitors Should Be Subject To Additional Protection To Avoid Unintended Circulation Of Information Within Firestone Several of the Firestone Requests call for the production of documents that may include sensitive, proprietary information belonging to Firestone's tire manufacturing competitors. Request Nos. 100 and 101, in particular, seek all documents relating in any way to the "selection 25
purchase, and/or procurement or any tire used or considered for use on Ford Explorers, Ford Bronco IIs and/or Ford Rangers" and all documents relating in any way to the "testing, analysis or review of any tire used or considered for use on Ford Explorers, Ford Bronco IIs and/or Ford Rangers." Ford has objected to these requests on the grounds, among others, that the requests "seek documents that contain confidential and proprietary information and that public disclosure of such information concerning Goodyear's, Michelin's or other tire manufacturers' trade secrets, confidential research, development and commercial information could cause competitive harm to tire manufacturers. Ford has attempted to provide discovery in a manner that respects the third parties' desire to maintain their trade secrets. Firestone argues that any information produced by Ford is fully protected by the March 7, 2001 Confidentiality Order entered in this case, that Ford has no standing to assert the confidentiality interests of third parties, and that Ford has failed to demonstrate why the requested documents contain confidential business information. Memorandum in Support at 25- 26. Firestone is wrong on all three counts. The requests at issue seek documents that would include pricing information, marketing information, testing information, manufacturing information and other material that is by its very essence proprietary. Without accusing Firestone of any impropriety, it is also obvious that such information could be used by Firestone, intentionally or unintentionally, to great competitive advantage. Once a Firestone employee has access to such information for purposes of this litigation, he or she is likely to consciously or subconsciously take such information into account when making business decisions. The human brain simply cannot be compartmentalized so as to prevent this from occurring. 26
While the Confidentiality Order may protect documents from disclosure to the public, Paragraph 7(g) expressly permits the disclosure of confidential documents to Firestone employees. Such disclosure creates a great risk of competitive harm to Firestone's competitors and raises antitrust concerns. North Atl. Instruments, Inc. v. Haber, 188 F.3d 38, 44-46 (2d Cir. 1999) (affirming decision to protect trade secret11 from disclosure in antitrust case); American Standard, Inc. v. Pfizer Inc., 828 F.2d 734, 741 (Fed. Cir. 1987) (noting that "[c]ourts have presumed that disclosure to a competitor is more harmful than disclosure to a noncompetitor") (citation omitted). Ford has a significant interest in protecting the information (much of which is subject to non-disclosure agreements) it obtains from its vendors. 12 Indeed, the type of material Ford receives from its vendors often represents the most advanced thinking in the industry. Some of the concepts or proposals contain either Ford or the vendors' attempts to design and manufacturer a better product than is on the road currently. For the same reason Firestone would not want to release this information to its competitors, Firestone's competitors desire the same. Ford does not suggest that Firestone has no right to production of relevant documents in Ford's possession containing information obtained from Firestone's competitors. As set forth above, Firestone's requests are over broad and should be narrowly limited to the information it needs to defend this case. For example, Firestone does not need information concerning the tires used or considered for use by Ford on the F-150. As for the competitor information that is 11 The Haber court defined a trade secret as "'any formula, pattern, device or compilation of information which is used in one's business, and which gives [the owner] an opportunity to obtain an advantage over competitors who do not know or use it.'" Haber, 188 F.3d at 44 (citation omitted). 12 Firestone's reliance on Burton Mechanical and Mike v. Dymon, Inc., Civ. A. No. 95-2405-EEO, 1996 WL 606362 (D. Kans. Oct. 17, 1996), is misplaced. In Burton Mechanical, an employee unsurprisingly lacked standing to assert protection of his employer's proprietary or confidential business information. Burton Mechanical, 148 F.R.D. at 234. Comparably, the plaintiff in Mike made no showing that the documents sought to be withheld were proprietary or confidential. Mike, 1996 WL 606362, at *3. Here, the sensitivity of information supplied to Ford by Firestone's direct competitors is apparent and is paramount to Firestone's competing concerns. 27
relevant, Ford suggests that the Confidentiality Order be modified to provide a heightened level of protection for such documents sharply limiting their disclosure to Firestone employees. Fed. R. Civ. P. 26(c)(7). Ford remains available to discuss this matter with Firestone in an effort to resolve this issue. VIII. Firestone's Contentions And Arguments Are Otherwise Without Merit Firestone raises a smattering of other concerns, none of which is a basis for relief. Firestone asserts that the batch printing feature of the forddocs.com website does not appear to work. Firestone Memorandum in Support, p. 22. While there have been isolated instances where individuals have had difficulty using different forddocs.com features, the difficulties have been resolved when brought to Ford's attention. Firestone brought this concern to Ford's contention in its motion to compel and in a telephone conversation among counsel on October 9, 2001. Ford has since arranged to speak with the appropriate technical support person at Jones Day Reavis & Pogue when he returns to his office on October 15, and presumably Firestone's difficulties will be resolved at that time. Others have experienced no difficulties with the batch printing feature, which Ford understands is fully operational. Firestone further suggests that Ford has failed to produce documents on CD ROM, purportedly as ordered by the Court in its March 15, 2001 Order. On the contrary, Ford has agreed to produce materials at Firestone's expense and has provided proposals from its vendors directly to Firestone's counsel. Firestone's counsel – perhaps to develop a discovery dispute – has insisted that Ford produce the material on CD ROM as opposed to other more economical methods. Ford stands ready, as it has, to produce the materials sought by Firestone subject to Firestone's agreement to pay the reasonable costs of producing documents in this manner. 28
Firestone complains that it has been prejudiced in its defense of this case as the result of Ford's alleged delay in responding to the Firestone Requests. Firestone Memorandum in Support, pp. 4-5.) Firestone has not suffered any prejudice. Firestone, like Ford, has conducted extensive investigations of the Firestone tire failures in connection with the NHTSA recall. Firestone has presumably retained many able consultants to analyze in detail the performance of its tires and the Ford Explorer. Firestone has defended numerous cases involving Firestone tires and the Ford Explorer, and has long had access to many Ford documents concerning the matters raised in this litigation. Firestone has had full access to forddocs.com since April and May, 2001. The Firestone Requests were not served on Ford until July 6, 2001, and Ford has timely responded to the requests. Aside from its conclusory complaint, Firestone fails to show any prejudice, and indeed there is none. Firestone also complains that Ford improperly refers Firestone to other means of discovery, including depositions, in lieu of producing documents responsive to the Firestone Requests. Firestone Memorandum in Support p. 24. While Ford has suggested in its objections that depositions would be a superior means of discovery concerning certain information requested by Firestone, Ford has not interposed this suggestion as the sole basis for refusing to produce documents. An example is Firestone Request Nos. 76 and 77. In these requests, Firestone seeks all documents relating in any way to the assertion in Ford's March 28, 2001 NHTSA Submission that "Explorers have a margin of safety as designed to accommodate, to a reasonable level, component failures including tread separations," and all documents relating to "the means and criteria used by Ford for determining what constitutes a 'reasonable level' of accommodation of component failures and/or tread/belt separations." Ford's assertion to NHTSA is an engineering 29
opinion based on the collective engineering wisdom and judgment of the Ford employees and consultants who conducted the root cause analysis of the Firestone tire failures. It is based on an extensive analysis conducted over a period of many months. It is also based on the broad experience of those who performed the analysis, gained over long careers in the automotive industry. While the extensive documentation underlying the root cause analysis produced on forddocs.com to date has been identified by Bates range, the request at issue, and others like it, does not lend itself to the production of a small, well-defined group of responsive documents. It is, as suggested in Ford's response, a matter better addressed through other means of discovery, including in particular, depositions. Finally, Firestone complains that Ford has failed to properly certify that it has produced "all" documents responsive to Firestone's requests. Firestone Memorandum in Support, pp. 13- 14. Pursuant to Rule 26(g), Ford must make a diligent inquiry and a reasonable search for the documents requested by Firestone, and produce all the responsive documents that it locates. Ford's discovery responses are signed by counsel and meet the requirements of Rule 26. While Ford's document sweep and production are ongoing, and while additional documents are being produced on a regular basis, Ford has complied with Rule 26, and has made a good faith, reasonable effort to locate and produce documents responsive to Firestone's requests within the bounds of relevancy. Rule 26(g) does not, however, require Ford to certify that it has produced "all" responsive documents, particularly in light of the overbreadth and vague and confusing 30
nature of the requests propounded by Firestone. 13 Rule 26 likewise does not require the production of documents that are not relevant. In re: Vitamin Antitrust Litig., supra, at *37. Ford's discovery responses are complete and proper and Firestone's Motion to Compel should be denied. CONCLUSION For the foregoing reasons, Firestone's motion to compel discovery should be denied. Dated: Respectfully submitted, ________________________________ John H. Beisner O'MELVENY & MYERS LLP 555 13th Street, N.W. Suite 500 West Washington, DC 20004-1109 (202) 383-5300 ________________________________ Randall R. Riggs LOCKE REYNOLDS LLP 1000 Capital Center South 201 N. Illinois Street Indianapolis, Indiana 46204 (317) 237-3814 COUNSEL FOR FORD MOTOR COMPANY 13 Firestone's assertion that it is "entitled" to such a certification under Ellman v. Hentges, No. 99 C 50269, 2001 WL 649508 (N.D. Ill. June 8, 2001), and Arkwright Mut. Ins. Co. v. National Union Fire Ins. Co. of Pittsburgh, No. 90 CIV. 7811 (AGS), 1994 WL 142064 (S.D.N.Y. Apr. 14, 1994), is mistaken. Although the district courts in those cases ordered the issuance of such a guarantee, Ellman, 2001 WL 649508, at *3; Arkwright, 1994 WL 142064, at *2, there is no general requirement under Rule 26 that such a certification occur as a matter of course. 31
CERTIFICATE OF SERVICE Service of the foregoing was made by hand delivery or by placing a copy of the same into the United States Mail, first class postage prepaid, this _____ day of _______________, 2001, addressed to all counsel of record appearing on the Panel Attorney Service List, and others, as necessary. ____________________________________ Randall R. Riggs LOCKE REYNOLDS LLP 201 N. Illinois Street, Suite 1000 P.O. Box 44961 Indianapolis, Indiana 46244-0961 (317) 237-3800 506028_1 32


text:
We still need a single-payer program. We have to go beyond the Affordable Care Act. Too many people are still suffering and dying prematurely.
Michigan's right-to-work law is about recreating the 19th century social order.
Bernard Weiner, PhD in government & international relations, has taught at universities in California and Washington, worked for two decades as a writer/editor for the San Francisco Chronicle, and currently serves as co-editor of The Crisis Papers (www.crisispapers.org). To comment: firstname.lastname@example.com.

subset: commoncrawl


text:
Black Mask
There are 50 cosplay photos tagged with "Black Mask (ブラックマスク)" of BATMAN. Photos that tagged with it's series are also submitted with tag Harley Quinn (3793), Poison Ivy (1418), The Joker (1393), Batman (670), Robin (442).
Register for a free account and meet cosplayers all over the world!


text:
All Schools
(5) All Schools
(5) High Schools
(3) High Schools
(3) Elementary Schools
(4) Elementary Schools
(4) Preschools
(3) Preschools
(3) Public Schools
(4) Public Schools
(5) All Schools
(5) High Schools
(3) High Schools
(3) Elementary Schools
(4) Elementary Schools
(4) Preschools
(3) Preschools
(3) Public Schools
(4) Public Schools
There are 5 private schools in zipcode 21239, MD, serving 951 students.
Minority enrollment is 67% of the student body, which is more than the MD state average of 35%.
The student:teacher ratio of 12:1 is higher than the state private school average of 9:1.
21239, Maryland Private Schools
- School Location Grades Students
Baltimore5407 Loch Raven Blvd
Baltimore, MD 21239
(410)433-2775(Roman Catholic)Gr. PK-8 | 391 students
Baltimore5701 Loch Raven Boulevard
Baltimore, MD 21239
(410)435-6961(Lutheran Church -- Missouri Synod)Gr. PK-6 | 59 students
Baltimore1300 E Northern Pkwy
Baltimore, MD 21239
(410)433-8880Gr. 9-12 | 309 students
All-girls(Roman Catholic)
Baltimore2000 E Belvedere Ave
Baltimore, MD 21239
(410)426-2309(Baptist)Gr. PK-12 | 136 students
Baltimore1301 Woodbourne Ave
Baltimore, MD 21239
(410)433-1000Gr. 6-12 | 56 students
All-boys | Alternative School
Zipcode Statistics
|About This Zipcode (21239)
|Zipcode Statistics
|(MD) State Statistics
|Population (Approximate)
|28,793 people
|5,731,109 people
|Age 25+ w/College Degree
|Median Household Income
Recent Articles
Updated July 12, 2015
Many parents tend to dismiss the idea of sending their children to private school without exploring it in depth. We explore this and several more related subjects.
When it comes to choosing a private school, there are so many choices to consider that the project can be a huge challenge to most of us. We offer some help and advice to help you get started.
Sending your child to a foreign language school makes good sense when you have been posted to this country from abroad and in other circumstances as well.


text:
Bringing the famous Pop star Robbie Williams who will give a live concert at Athens in 20/07/2015..
9H-MTF departs Geneva
First ray of sun on P48 apron ...
Sat on stand between charters.
Parked up for the night.
Special chartered B733 having the famous Pop Star, Lady Gaga onboard seen here preparing for a flight to BRU continuing her "artRAVE" Tour !! (1200pix)


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Paradise Burning, or Why We All Need to Learn the Word 'Anthropogenic'
30 Years Gone, and Oh, How We Still Love Orson Welles
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Waging endless war in the Middle East means not only turning old enemies into allies but exposing our inability to free ourselves from the mechanisms of violence and collapse.
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With multiple gadgets and screens constantly running, and perhaps even a different sense of time than our forebears had, it's no surprise that powering down long enough to curl up with a book is becoming an endangered activity—although, as David L. Ulin argues in the Los Angeles Times, it's still a very vital contemplative practice to pursue.
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Red Sox Wedding Cake Topper
Posted by jaambageek on Aug. 02, 2007
Break proves that nature is one badass mother f**ker!
2015 is already halfway over!! We assembled a panel of critics to pick the ...
Become a Breaker! ?? http-//bit.ly/BreakSubscribe Kevin's Shia Lebeouf Moti...
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"As good as Book One"
An intelligent and engaging finale. You should read books one and two of the series. I expected Book Three to be anticlimatic, but it very much held my interest.
"Great trilogy!"
This author keeps you wanting more, exciting, intrigue, and plenty of action. I have all his books and this final book still has unanswered questions, but we will never know. This author will be missed.
Riveting! Although I thought I knew how it would end I didn't. This author was masterful in weaving all of the threads of a story together and tying all the ends up. I have read where there is a 4th novel but caught up in red tape about publishing. That almost sounds like a story in itself. Maybe one for the life partner to write. I heartily recommend this book to all who like fiction that keeps you going . . .to the end.
"Great Story"
It's an excellent trilogy, this being the third book. I truly enjoyed the story.
I just saw the movie of the first book "The girl with Dragon Tattoo" it was in Swedish with English subtitle. The Lisbeth character was excellently portrayed, but a lot of details we naturally missing. Hope they make movies of the 2-nd and 3-rd (this book). To follow the story must start read the books in sequence.
Narrator was excellent too.
"Excellent !!!!!"
What a great trilogy. Simon Vance does an amazing job narrating. Well worth the credits for all three books. I am sorry to see these characters come to an end just as we are really get to know them. A great series like this one does not come around often enough.
"Incredibly done!"
So sad that this is the end. The characters are very well developed. Narration was phenomenal! A couple of the areas could've used shorter explanation, but the story was very thorough and unfolded well. Lisbeth Salander is my SHERO! Stieg RIP...you done good!
"The best in the Trilogy"
taking amazing story started with the Dragon Tattoo, and developing to new heights.
the first is better then the second, but the third is above both.
do not Skip any of them, keep the order.
last hour was not a must, but it might be the base to the forth we will never have... pity.
"Best of the series"
I thought this one was the best of the trilogy. I went back and listened to all three in order since it had been a while since I read the first one.
This is the best of the three - a great read -
"The Girl Who Kicked the Hornet's Nest"
Fantastic sequel. What a joy to hear Simon Vance's voice again. He is such a remarkably talented narrator. This is one of the best book series I have ever "read". What a wonderful surprise. I could not wait to get to this book in the car, on my itouch and every spare minute. Terribly sad that such a talented author died primaturely.


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More than 40,000 high temperature records have been broken in the U.S. so far this year. With that kind of heat, you'd think the Earth was close enough to the sun to hold hands.
But actually, it's quite the opposite. This week, the Earth is at its farthest point from the sun than it will be all year.
This seeming paradox occurs when our planet comes to a point in its orbit called the "aphelion," the spot Earth reaches on its elliptical orbit when it is farthest from the sun.
At midnight EDT on July 5, the Earth will be about 1.5 million miles farther than it usually is from the sun.
The reasoning behind this paradox has to do with the Earth's tilt, not its distance, said AccuWeather Meteorologist Mark Paquette.
"It's a misunderstood phenomenon," Paquette said. "Most people [in the Northern Hemisphere] think, 'OK, it's summer. The Earth must be closest to the sun,' when really it's the exact opposite."
The U.S. can blame the Earth's 23.5-degree tilt for this month's intense heat waves. During summer, the Northern Hemisphere tilts toward the sun. Even though the planet is farther from the sun, continents in its direct rays will receive three times as much heat as they do in winter months, when the Earth is closest to the sun.
This "tilted" concept occurs again in January during the perihelion, when Earth is closer to the sun by more than 3 million miles than it is at the aphelion.
During the perihelion in the Northern Hemisphere's winter, the planet receives 7 percent more sunshine, but because our hemisphere tilts away from the sun, we have colder temperatures and snowy weather while regions in the Southern Hemisphere enjoy their summer.
A disturbance will swing across the Midwest and fire a round of severe thunderstorms to end the weekend.
Hurricane Guillermo will continue its path towards Hawaii in the coming days bringing large swells and enhanced rainfall to the islands.
Cooler conditions will move into the Interior Northeast early this week, but the warmth will hold on a little longer along the Interstate-95 corridor.
After a very hot end to July, some relief is on the way this week for Seattle and other areas of the Northwest.
After months of below-normal rainfall, Santiago, Chile, could finally receive several days of rainfall this week.
One person is dead and multiple people are injured after a tent collapsed during a thunderstorm at a festival in suburban Chicago, the Chicago Tribune reports.
Boise, ID (2000)
2 small tornadoes passed just south of the airport.
Waterville, NY (2007)
Thunderstorm winds blew large, heavy and bolted down sheds 500 feet onto the roadway.
Philadelphia, PA/ Camden, NJ (1885)
Tornado struck, cutting an 8 mile path, crossed river near present day Walt Whitman Bridge; 5 killed, $500,000 damage. Total of 13 tornadoes within 100 miles of Philadelphia. Street flooding and flooding of homes.


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Various Authors 9:01 p.m., July 27
Being a tourist from Germany, one of my first actions in Southern California was fulfilling a long-dreamed dream: purchasing a lovely beach cruiser. Those bikes are rare and hard to get in Germany, so my ...
Various Authors 9:01 p.m., July 27
Carrie O'Connell 8 p.m., July 27
Jon Reimer 6 p.m., July 27
Jeff Smith 2 p.m., July 27
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Matt Potter 12:42 p.m., July 27
Daniel Powell 11:45 a.m., July 27
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Fractal Design Newton R3 800-Watt 80 PLUS Platinum Power Supply Review - Cabling Arrangement and A Look Inside
Cabling Arrangement
The Fractal Design Newton R3 comes with a cable for just about everything you'd want and need. The only thing that I'm not much of a fan of is that two of the PCI-E cables are natively wired and I would like to see that only one of them be this way. It is my experience that most users of 700W-800W power supplies only have a single GPU in their system, so that leaves an unnecessary cable just hanging inside the PC. Other than that, there isn't anything to complain about.
Rail distribution is as simple as it gets with a single 12V rail. There is no need to worry about load balancing here.
A Look Inside
Plenty of passive cooling is present with a layout that isn't overly crowded. There are also some green and gold capacitors in the top left which doesn't look good for that claim of 100% Japanese capacitors on the back of the back of the box.
A pair of Nippon Chemi-Con bulk capacitors sit on the primary side of the power supply.
The secondary side is littered with a bunch of Teapo caps. This is the first time that we've caught someone stating that their units featured 100% Japanese capacitors and it didn't, so we certainly aren't happy about this at all.
Fractal Design uses their own 140mm fan to provide the active cooling for the Newton R3 800W power supply and it is rubber mounted to help reduce noise from vibrations.
PRICING: You can find products similar to this one for sale below.
United States: Find other tech and computer products like this over at Amazon's website.
United Kingdom: Find other tech and computer products like this over at Amazon UK's website.
Australia: Find other tech and computer products like this over at PLE Computer's website.
Canada: Find other tech and computer products like this over at Amazon Canada's website.
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- Page 3 [Inside the Box]
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Cobre's Marisa Macon poured in 27 points during the first round of tourney action against Lordsburg on Monday night. The Lady Indians still fell short in the contest, 49-48.
Jail inmate in Arizona pulls eye out of its socket
FLORENCE, Ariz. (AP) — A jail inmate in Arizona is hospitalized after authorities say he pulled one of his eyeballs out of its socket. Full Story
Guest lineups for the Sunday news shows
WASHINGTON (AP) — Guest lineups for the Sunday TV news shows: ——— ABC's "This Week" — Sen. Full Story
J.J. Abrams broke his back filming 'Star Wars'
The 'Star Wars: Episode VII -- The Force Awakens' director reveals to Jon Stewart how the Millennium Falcon door that injured Harrison Ford on set also broke Abrams' back.


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New Galilee Jobs
Looking for jobs in New Galilee? Snagajob has great opportunities with the area's leading companies. And applying for New Galilee jobs has never been easier. Look at the job listings below, click on a job title that interests you and hit the "apply now" button. Part-time jobs, teen jobs, student jobs and summer jobs are now just a click away. Start your job search now.
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Welcome to ringtone download service Audiko.net, where you can aquire the best ringtones for your smartphone. Today we have a ringtone of "Bo mam Ciebie" by Sumptuastic as well as 29 other ringtones by Sumptuastic. "Bo mam Ciebie" is one of the best tracks from the "Cisza" album that was composed by Sumptuastic at their recording studio together with other 4 tracks. You can listen to all 4 Sumptuastic – "Bo mam Ciebie" ringtone variations available here and download it for free to your computer. You can also choose from other 2 albums produced by Sumptuastic for all time. "Bo mam Ciebie" is referred to Polish, and we have a huge amount of Polish collaborations absolutely for free. And finally, we have collected lyrics for this track and you can view it here as well. So feel free to browse, listen, download ringtones at Audiko.net. Make your phone sound cool!
Sumptuastic Bo mam Ciebie Ringtone
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Calhoun County Historical Commission to Read Texas Declaration Tuesday
The Calhoun County Historical Commission will host the Texas Declaration of Independence at noon Tuesday, March 3 at the Calhoun County Museum, 301 S Ann Street in Port Lavaca.
The Calhoun County Historical Commission will host the Texas Declaration of Independence at noon Tuesday, March 3 at the Calhoun County Museum, 301 S Ann Street in Port Lavaca.
The Redneck Messiah is back with the followup to his 2014 No. 1 smash, 'Panhandle Poorboy.' For his latest radio single and music video, 'Before Somebody Gets Hurt,' Fowler calls on Amy Rankin of the Rankin Twins for help. Give the video a watch, then watch as the song soars up the Texas charts.
Multi-media company DreamVision has announced plans to open a new $3.5 billion theme park in the Fort Worth area by 2020.
Wichita Falls resident Tim Norris says he wanted to protest high taxes but he ended up arrested instead.
Texas is known for many things, including the phrase, "Everything's bigger in Texas." The phrase is true about many things in the Lone Star State, including its fast food offerings.
One native Texan has taken to Change.org to challenge Southern fast food titan Whataburger to do something a little different to its menu.
Recently, Home Shield Security, compiled a list of the most dangerous cities in Texas. You may have seen it, the list has been making it's way around Facebook and Twitter. This particular list takes in to account BOTH violent and property crimes. The data came from the FBI website, and you may be surprised where your city lands -- or not.
The Houston Livestock Show and Rodeo has announced their entertainment lineup for 2015. It is as follows;
Wednesday, March 4* – Armed Forces Appreciation Day sponsored by BHP Billiton - Hunter Hayes
Thursday, March 5 - Miranda Lambert
Friday, March 6 – Black Heritage Day, sponsored by Kroger - John Legend
According to a news release from the Texas State Comptroller's Office, Victoria County residents may have money waiting for them in the state's Unclaimed Property database, and they'll have an opportunity to search for it at an upcoming event hosted by the Texas Comptroller's office and Victoria County Treasurer Sean Kennedy. Representatives from the Comptroller's office will help people search for unclaimed property online, fill out claim forms and answer questions from 10 a.m. to 6 p.m. on Wednesday, Jan. 14, in the Pattie Dodson Public Health Center at 2805 N. Navarro in Victoria.
The Texas Department of Criminal Justice will host a hiring seminar at 6:30 p.m. Thursday at the Guadalupe Valley Electrical Cooperative, 1015 E. Broadway St., in Cuero. There are several staff openings for both full and part-time correctional officers at area prison units.
'Tis better to give than receive. Never has that old staple of the Christmas season been truer than it was last week at a fast food restaurant in Liberty, Texas.
Good news my fellow Texans, we're livin' good. I mean, we all knew that, but it's always nice to read data that reinforces what we know to be absolutely true. The only states ranked better than the Lone Star State as most affordable states to live in: Kansas, our friends to the north, Oklahoma, and Nebraska. But, c'mon, Kansas and Nebraska? Really?


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I'm an Asprin and now with Jodi-lynne-Nye "Myth"-books addict.Published 17 days ago by Bradleyman31
These stories were some that were read years before and now the kids love to read. Just glad they can be purchased again after all these years!Published 8 months ago by Jenn
I enjoy this series. Been hooked. Light read but fun. Would recommend.Published 9 months ago by S. Poudrier
Robert Asprin has been collaborating with Jody Lynn Nye on the Myth series since 2002, For those of us who read the whole series, we can detect the influence that the new author... Read morePublished 12 months ago by Jim Phillips
Well, I've been hoping against hope for the light-hearted comedy that was the Myth Adventure series by Robert Asprin. Read morePublished 13 months ago by Ikky-san


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Leeda assassin float rod 13/15 ft
Leeda float rod really good condition...can be used at 2 different lengths...no offers 15 located in Newport
Leeda float rod really good condition...can be used at 2 different lengths...no offers 15 located in Newport
Top half has broken grab a bargain. Fox warrior xt slim rod 3lb tc
A pair of fladen beach rods 12 ft 3 piece brand new ideal for travel rods collect only
A pair of hardwear beachcaster 14ft 2 piece rod made for long distance casting used twice good condition bargain. Collect only
Daiwa moonraker beachcaster 12 ft good condition. Collect only bargain ................... .
shimano hyperloop bx carp rod 12ft/2pc/2.75lbtc vgc pick up only from Pontypridd area £25
two fox warrior xt carp rods 12ft / 2pc/3lbtc vgc sold as a pair pick up only from Pontypridd area
Classic milbro enterprise 14 half ft course rod 40 yrs 0ld plus .collect only
Classic abu Atlantic beachcaster.hardly a mark on it for a 40 yr old plus rod bargain. Collect only
Classic abu Atlantic 484 zoom 40 yrs 0ld plus rough but totally usable collect only
Army issue sleeping bag for all seasons in bag £20 Newport South wales
Dyna craft bait boat with 7ah battery in full working order in handy bag£160ono Newport South wales
Brand new boxed machine cut traditional centre pin reel. 4.25inches with stainless steel shaft. One piece machine cut frame. Weighs only 22 grams and run forever, super smooth ultra running reel.fully adjustable drag system.
Great used condition, it doesn't fit our new camera so need to sell.
Fresh water fishing rod with reel ...shimano scabard in good condition £30.00
Various fishing equipment everything you need. Ready for fishing £170 ono mixed carp, match and spinning rod. Bite alarms etc..
FLEXTEC GR X 88 SERIES FLY ROD 10ft 6in 3PIECE AFTM 7/8 WYCHWOOD TRUFLY REEL LIMITED EDITION with SPARE SPOOL COURTLAND 444 FLOATING XP TAPER LINE 2BOXES FLY APPROX 100 FLIES LANDING NET ODDS and ENDS ECT ALL IN EXCELLENT CONDITION £80....... L
penn 525 tournament & abu 6500 magelite multipliers. both in good working order and condition.
Hear I'm selling a sl30 brandnew with box oil and tool. Lovely strong bullet proof reels £60 contact dave on 07506941154
Hear we have a jd300 multiplyer gear ratio 4.2.1 very good used condition £10 contact dave on 07506941154
Hear I have a multi x 5000 II gear ratio 5 2 1 4 ball bearings £10 contact dave on 07506941154
Outbound mummy sleeping bag. Thick very warm, cotton material inside. Zip working fine. Used but good condition
SEALINE SL20SH Daiwa powermesh drive fishing reals x 2 £80 ONO malpas used but in full working order , no boxes or tools included
Aley bait pump . Use a few time good toy coz me£60 for sale now so £20 cheers
Large boat fishing net Ideal for a big fishing but selling due to it being to big for my boat. Grab a bargain £10!


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New Diamond 1.00 Ct 18k Wg Teardrop Pendant Necklace *gal Appraisal *gift Box For Sale
mhab Store
This exquisite, new, 18kt White Gold and 1.00 ct tw DIAMONDTEARDROP Pendant is a classic design and is the perfect gift for that someone special. The chain features a lobster claw closure.
We ship in a tasteful presentation box ready to add to your personal collection or present as a gift.
Hallmarked: The pendant is marked 18K; The chain is marked RC 18KT INDONESIA. The lobster claw is marked 750.
Condition: Excellent – new without tags
Dimensions: The pendant measures approximately 1/2 inch x 3/8 inch. The chain measures 16 inches long.
Diamonds:Shape & Cut: Round Brilliant Weight: 1.00 cts tw Color: G-H Clarity: VS
Estimated Retail Value: $1475
Thank you for viewing this item. Please check out our other listings on .
The GEMOLOGICAL APPRAISAL LABORATORY OF AMERICA, Inc. is a reputable independent diamond and jewelry appraisal service located at the center of the diamond district in New York City. GAL appraisals are recognized by all insurance companies.
For over 25 years, the Gemological Appraisal Laboratory of America, Inc. (GAL) has offered both the jewelry trade and consumers' accurate and reliable diamond and gemstone identification and certification to validate their gemstone purchases as well as the current retail replacement value of the item. All the Appraisers are experienced GIA Graduate.
This item has been shown 167 times.
New Diamond 1.00 Ct 18k Wg Teardrop Pendant Necklace *gal Appraisal *gift Box:
Penny Preville 18k Yellow Gold Engravable Charm Pave Diamonds - Reduced Price
Roberto Coin Yellow Gold Martella Flower Diamond Bangle
Roberto Coin 18k Yellow Gold Martella Flower Diamond Necklace- Reduced Price
14k Yellow Gold H Si1 Quality Pave Set Diamond Circle Pendant Carat Wt- 0.588ct
3.10 Carat D-vvs1 Ideal Round Certified Diamond 18k Gold Classic Pendant 4.38g
14k White Gold Diamond Pave Heart Pendant 0.50ct 2.7 Grams No 2166
14k White Gold Black & White Diamond Knot Pendant. Carat Wt- 0.5ct
14k White Gold G-h Si2 Quality Diamond Cross Pendant. Carat Wt- 0.084ct
14k Two Tone Gold Diamond Double Heart Pendant Carat Wt- 0.1ct. Metal Wt-1.23g
18k White Gold 0.35ct Classic Mirror Inpsired Bezel Set Diamond Octagon Pendant


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Car was painted 2 years ago. Interior is all black and was completely redone 2 years ago. Front end with hideaway headlights.350ci engine completely rebuilt... More
1967 Chevrolet Camaro RS/SS Convertible, 48,000 miles, totally original survivor, rust free, nice Bolero Red paint, Black power top, Deluxe Red interior, loaded with... More
This 1967 Chevrolet Camaro RS is honest, original, and just plain amazing. It's a real Rally Sport with all the right features in... More
Split bumper clone, nice body, nice redone interior, new steel cowl hood, built V8, auto, ps, pb, corvette rally wheels, wrapped in new BF... More
This stunning 1968 Chevrolet Camaro SS 2 Door Coupe is an original, numbers matching big block car. Painted in an original shade of... More
1969 X44 YENKO TRIBUTE HUGGER ORANGE CAMARO COMING SOON ASSEMBLING NOW - BUFF - STRIPE - DETAILS THE FINISHED CARS BELOW ARE WHAT... More
WORLDWIDE VINTAGE AUTOS CALL OUR SALES TEAM: 720-457-9145 MONDAY-FRIDAY: 10AM-5PM SATURDAY: 10AM-4PM AS ONE OF THE LARGEST... More
1968 Chevrolet Camaro Numbers Matching 327 CI V-8 Engine Automatic Transmission Power steering Power brakes Factory air conditioning Houndstooth seats Deluxe interior Redline tires Original Protect-O-Plate Original owner's manual... More
1968 Chevrolet Camaro Convertible for sale in our Indianapolis Showroom. This 68 Convertible Camaro is powered by a 327 CID V8 engine backed by... More
Now for Sale in our Livermore, California Showroom. Meticulously Restored 1968 Chevrolet Camaro Rally Sport Coupe. Rebuilt 350 V-8 engine. Less then 100 miles on... More
CHEVROLET 1969 CAMARO SPORTS COUPE, restored with cosmetic Z28 appearance, stunning red and Z28 striping, cowl induction hood, bult dated 350cid/4v, ceramic headers to... More
1987 Camaro Z28 - Only 63k original miles!! T-Tops! Original motor, automatic trans, interior and color. 1 "touch up" paint work. Excellent original interior.... More
In the days of 650 horsepower production pony cars and companies that engineer modern performance products for anything from a Civic to a Cadillac... More
SUMMARYShowroom-fresh Hot Wheels Camaro with only 2482 actual miles1 of only 314 Hot Wheels Camaro convertibles produced1 of only 57 Hot Wheels Camaro convertibles... More
SUMMARYNational award winner / Awards included with the car's sale468 cubic inch fuel injected V8Tremec 6-speed manual transmissionVintage Air conditioning / Custom Kicker-certified audio... More


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This is site doesn't just find educational videos, but it can find specific words or phrases within the script of the video and help you find them in context. Very useful tool.
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Anita Vance's curator insight, February 5, 12:40 PM
Always worthwhile to keep up with Joyce Valenza! Here are her suggestions for keeping up....thanks to John Evans!
David Baker's curator insight, February 8, 11:40 AM
Librarians are vital as we move 1:1. The resources are changing but the need for text and learning are never greater.
From ALA - a radio interview that positively describes modern school libraries and librarians.