THE MEAD CORPORATION'S REPLY IN SUPPORT OF ITS MOTION FOR PROTECTIVE ORDER AND RESPONSE TO BEAZER EAST, INC.'S CROSS-MOTION TO COMPEL MORE SPECIFIC RESPONSES FROM DEFENDANT

摘要

For the foregoing reasons, Mead respectfully requests that this Court deny Beazer's Cross-Motion to Compel More Specific Testimony, and issue a permanent protective order limiting Beazer's inquiry into Subject Areas 10, 13 and 14 in its Notice of Rule 30(b)(6) Deposition to the discovery regarding the former Woodward operations owned by Mead obtained through the September 17, 2010 Rule 30(b)(6) deposition of Mead.