2. Background

CPSD claims that Clear World's responses to the data and document requests set forth in Appendix A of the OII are incomplete and, as to the information supplied, lack proper verification. Among other things that are more generally stated, CPSD seeks an order requiring further response to the following:


· Telephone numbers of employees;


· Compensation paid to James, Michael, Joseph and Christopher Mancuso;


· Specified banking and financial information;


· Notes and switching information for 69 customers who alleged that they were slammed;


· Information on direct billed customers and revenue they produced;


· Information on the purchase of predecessor companies;


· Data on payment of public interest surcharges;


· Verification by appropriate custodians; and


· Verifications by James Mancuso and Michael Mancuso.

Clear World argues that it already has supplied thousands of documents to CPSD, that much of the additional information sought could have been resolved in a good faith "meet and confer," and that depositions scheduled by CPSD for August 12, 2004, in Los Angeles with two executives of Clear World's accountancy firm, Stephens, Reidinger Beller LLP, are likely to provide much of the information sought in the motion to compel.

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