TURN Motion to Compel Further Data Request Responses from Pacific Bell

TURN and Pacific resolved all items in motion except those reflected below:

Data Request

14 Pacific not required to review individual contracts, but shall conduct reasonable and diligent search for high level/summary memos/reports, report to TURN on the results of its search by 6/14/02, and produce such information so that it is in TURN's hands by 7/1/02.

24 full and complete response due in TURN's hands 7/1/02 re second and third years in future (Pacific agreed voluntarily re first year in future)

25 full and complete response due in TURN's hands 7/1/02

36 limit to records of SBC Pacific and SBC Corporate/Texas only. Response due in TURN's hands 7/1/02.

39 full and complete response due in TURN's hands 5/31/02

40 same as 39

41 limit to high level reports/memos and team summaries; results due in TURN's hands 5/31/02

42 limit to ASI California and ASI national headquarters, and executives at VP level and above; results due in TURN's hands 5/31/02

43 no response required; relevance objection sustained

44 same as 43

46 limit to ASI California and ASI national headquarters; results due in TURN's hands 7/1/02