Discovery Fight

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES ex rel. FLOYD
LANDIS,

Plaintiff,

v.

TAILWIND SPORTS CORPORATION,
et al.,

Defendants.
___________________________________
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No. 1:10-cv-00976-CRC

Telephonic Conference
With Court Scheduled For
September 5, 2014
2:00PM

JOINT SUMMARY OF DISCOVERY ISSUES BY RELATOR FLOYD
LANDIS AND DEFENDANTS CAPITAL SPORTS AND ENTERTAINMENT
HOLDINGS, INC. (CSE), WILLIAM STAPLETON AND BARTON
KNAGGS (COLLECTIVELY THE CSE DEFENDANTS) REGARDING
RELATORS FIRST SET OF REQUESTS FOR PRODUCTION AND FIRST
SET OF INTERROGATORIES
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In order to comply with the page limit set by the Court and still reasonably outline their respective
positions on the outstanding issues, the parties have limited the argument portion of this submission to three
pages, which excludes this cover page and the signature page. The interrogatories and responses thereto
can be found at Exhibits A and B respectively. The requests for production and amended responses thereto
can be found at Exhibits C and D.
Case 1:10-cv-00976-CRC Document 215 Filed 09/04/14 Page 1 of 5
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I. INTERROGATORIES TO CSE
Relators Position - Interrogatory No. 1: CSE has refused to respond to this
interrogatory which seeks information regarding persons knowledgeable about doping
during the relevant period. See Exhibit B at p. 8-10. Relator has agreed to narrow the
definition of YOU for this request, so CSE would only have to provide information
from the current owners, officers, employees and agents of the company.
CSEs Position - Interrogatory No. 1: In meet and confer discussions, Relator
clarified that the Interrogatory requests CSEs current knowledge or belief as to
individuals who knew or who CSE believes knew about doping at any point between
January 1, 1995 and February 28, 2010. The Interrogatory requests speculative,
irrelevant information. It essentially requests based on all the information in the
public record that CSE guess who may have known about Armstrong or other
riders doping almost 20 years ago. The information provided would illuminate
nothing more than which individuals closely followed the press coverage of the
Armstrong saga. CSE does not object to Relators amended definition of CSE.
Relators Position - Interrogatory No. 9: Interrogatory No. 9 asks CSE to DESCRIBE
each and every action YOU have taken, or directed be taken, to locate, maintain or
preserve responsive DOCUMENTS . . . . Ex. B at 20-21. CSEs response provides no
meaningful details regarding what files or records were searched or how they were
searched. The CSE Defendants have also refused to disclose the search terms they are
using to locate documents in response to relators document requests. See Ex. D at 4.
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CSEs Position - Interrogatory No. 9: CSE responded to the Interrogatory by providing
the details of its search for responsive documents, but Relator was unsatisfied with the
level of detail provided. CSE believes its response to Interrogatory No. 9 is adequate.

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See DeGeer v. Gillis, 755 F. Supp.2d 909, 929 (N.D. Ill. 2010) (responding party should have disclosed
search terms and data custodians); Apple, Inc. v. Samsung Electronics, Co., 2013 WL 1942163 at *3 (N.D.
Cal. May 9, 2103) (adopting same standard); In re: Porsche Cars North America, 2012 WL 4361430 at *7
(S.D. Ohio Sept. 25, 2012) (defendants compelled to provide information regarding the steps they took to
locate and produce responsive documents); Romero v. Allstate Insurance Co., 271 F.R.D. 96, 109-10
(E.D. Pa. 2010) (compelling parties to agree on search methodology for ESI) (citing, inter alia, Doe v. Dist.
of Columbia, 230 F.R.D. 47, 56 (D.D.C. 2005)).
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Similarly, Relator demands CSEs search terms to purportedly gauge whether the
searches are reasonable. Relator has not stated any grounds to find CSEs searches
unreasonable and has none. Relators counsel is merely seeking to further burden CSE
and prolong already protracted discovery discussions.
III. DOCUMENT REQUESTS TO THE CSE DEFENDANTS
Relators Position - Request No. 69 seeks documents known by the CSE Defendants
to contradict the plaintiffs allegations. The CSE Defendants declined to produce the
documents.
Relators Position - Request No. 70 seeks documents upon which the CSE
Defendants rely to deny relators allegations against them. Defendants declined to
produce the documents.
CSEs Position - Request Nos. 69 & 70: As a practical matter the Requests are
overbroad and impossible to search for. The CSE Defendants cannot comb through
Relators 277-paragraph and the United States 93-paragraph complaints line-by-line
and compare the allegations to each document they possess to determine if they
conflict. Furthermore, documents responsive to these Requests are likely subsumed
under the 275 other document requests Relator served on the CSE Defendants.
Relators Position - Request No. 78 seeks documents that describe the nature of the
services any of the CSE Defendants have provided for Lance Armstrong from 1995
through the present. This request is relevant to Armstrongs claims of attorney-client
privilege with Stapleton. The CSE Defendants response excludes relevant
responsive documents.
Relators Position - Request No. 80 seeks documents showing the lack of an
attorney-client relationship between Armstrong and the CSE Defendants. These
documents are relevant, for Stapleton was not authorized to practice law during a
substantial part of the period relevant to this case. Defendants response
impermissibly narrows the request.
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CSEs Position - Request Nos. 78 & 80: Despite their vagueness, CSE endeavored
to interpret the requests and agreed to produce (1) all contracts or engagement letters
between the CSE Defendants and Armstrong, (2) all documents reflecting Stapletons
status with the Texas bar, and (3) all communications between Stapleton and
Armstrong in which a party expressly states Stapleton was or was not acting as
Armstrongs attorney. The documents CSE agreed to produce are adequate.
Relators Position - Request No. 88 seeks documents identifying CSEs officers,
directors, employees and agents. Relator is prepared to narrow the request to include
all of CSEs officers and directors, plus employees who worked full or part-time for
CSEs sports group.
CSEs Position - Request No. 88: Given the nature of CSEs business, CSE has had
many transient employees. CSE has agreed to produce documents sufficient to show
the officers, directors, and full-time employees of CSEs sports group. Providing
further information, if possible, would be highly burdensome and valueless.
Relators Position - Request No. 89 seeks CSEs board minutes, which are likely to
contain evidence relating to the allegations in the case. They are also relevant to
relators piercing allegations, since the CSE Defendants have said they did not hold
board meetings. Any formal or informal minutes should be provided.
CSEs Position - Request No. 89: As CSE stated in its response to Relators
Interrogatory No. 11, CSE has no formal board minutes.
Relators Position - Request No. 92 seeks documents or communications relating to
books relating to cycling or doping where the author or subject of the book, in whole
or part, is one of the Defendants. Relator narrowed this request to exclude published
books. Defendants amended response mischaracterizes the parties discussions on
this point.
CSEs Position - Request No. 92: During meet and confer correspondence, Relators
position as to what was included in the Request continually changed. Given the lack
of clarity, Stapleton and Knaggs cannot respond to the Request.
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Dated: September 4, 2014

Respectfully submitted,

__________ /s/________________
Paul D. Scott
pdscott@lopds.com
California State Bar No. 145975
Admitted Pro Hac Vice

___________/s/________________
Lani Anne Remick
laremick@lopds.com
U.S.D.C. No. PA0045
Jon L. Praed
U.S.D.C. No. 450764
D.C. Bar No. 51665
LAW OFFICES OF PAUL D. SCOTT, P.C.
Pier 9, Suite 100
San Francisco, California 94111
Tel: (415) 981-1212
Fax: (415) 981-1215

Attorneys for Relator Floyd Landis
/s/ John P. Pierce
John P. Pierce (D.C. Bar No. 475101)
THEMIS PLLC
2305 Calvert Street, NW
Washington, DC 20008
(202) 567-2050 Telephone
(202) 567-2051 Facsimile
jpierce@themis.us.com

Marc S. Harris (pro hac vice)
SCHEPER KIM & HARRIS LLP
601 West Fifth Street, 12th Floor
Los Angeles, CA 90071-2025
(213) 613-4655 Telephone
(213) 613-4656 Facsimile
mharris@scheperkim.com

Attorneys for Defendants Capital
Sports & Entertainment Holdings,
Inc., William J. Stapleton and Barton
B. Knaggs


United States ex rel. Landis v. Tailwind, et al.
Case No. 1:10-cv-00976-RLW (D.D.C.)

EXHIBIT A

JOINT SUMMARY OF DISCOVERY ISSUES BY RELATOR FLOYD LANDIS
AND DEFENDANTS CAPITAL SPORTS AND ENTERTAINMENT HOLDINGS,
INC. (CSE), WILLIAM STAPLETON AND BARTON KNAGGS
(COLLECTIVELY THE CSE DEFENDANTS) REGARDING RELATORS
FIRST SET OF REQUESTS FOR PRODUCTION AND FIRST SET OF
INTERROGATORIES
Case 1:10-cv-00976-CRC Document 215-1 Filed 09/04/14 Page 1 of 21
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UNITED STATES OF AMERICA
ex rel. FLOYD LANDIS,

Plaintiffs,

v.

et al.,

Defendants.
___________________________________
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No. 1:10-cv-00976-RLW

RELATORS FIRST SET OF INTERROGATORIES TO DEFENDANT
CAPITAL SPORTS AND ENTERTAINMENT HOLDINGS, INC.

Pursuant to Rule 33 of the Federal Rules of Civil Procedure and Local Civil Rule
26.2 of the Rules of the United States District Court for the District of Columbia, relator
Floyd Landis hereby propounds the following First Set of Interrogatories to the above-
named defendant and requests that defendant respond in writing and under oath within 30
days.
DEFINITIONS AND INSTRUCTIONS
These Interrogatories shall be interpreted and answered, and any responsive
materials shall be produced, in accordance with the following Definitions and
Instructions.
DEFINITIONS
The following definitions, whether or not capitalized, shall apply to each Request below:
1. ALL -- The term ALL is intended to be construed in the broadest
possible manner so as to include, but not be limited to, each and every.
2. AND / OR -- The words "AND" and "OR" shall mean "and/or."
3. ANY -- The term ANY means one or more.
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4. COMMUNICATION -- The term "COMMUNICATION" means a
transmittal of information, or request for information, by DOCUMENT or otherwise and
includes any conversation in person, by telephone or by any other means, as well as any
utterance heard by another person whether in person, by telephone or otherwise.
5. CSE -- The term CSE means Capital Sports and Entertainment
Holdings, Inc. and any d/b/as thereof, along with any person or entity known to YOU to
have acted or purported to act on its behalf, including but not limited to employees,
directors, officers, representatives, attorneys, contractors, consultants, agents, owners,
shareholders, subsidiaries, branches, divisions, units, affiliates, assigns, and predecessors
or successors in interest.
6. CSE RELATED ENTITIES -- The term CSE RELATED ENTITIES
means CSE, Capital Sports Ventures, and Capital Sports & Entertainment, Inc.
7. DEFENDANTS -- The term DEFENDANTS means TAILWIND,
ROSS INVESTMENTS, INC., CSE, Lance Armstrong, Johan Bruyneel, Thomas W.
Weisel, William J. Stapleton and Barton B. Knaggs.
8. DESCRIBE, EXPLAIN, STATE, or IDENTIFY, when used in
reference to any fact, occurrence, transaction, statement or other matter means to describe
and identify with particularity the facts constituting such matter, providing the date, time,
place, manner, and identity of the person(s) or entity(ies) involved.
9. DOCUMENT -- The term DOCUMENT refers to, means, and includes
all written or graphic matter or tangible things of every kind and description, however
produced or reproduced, in YOUR actual or constructive possession, custody, or control,
including but not limited to all originals (or copies where originals are unobtainable or
where the copies are not identical to the originals) of correspondence, emails,
memoranda, reports, applications, claims, policies of insurance, printed matter, contracts,
agreements, proposals, bids, work papers, statistical records, minutes, interoffice
communications, studies, technical data, charts, brochures, electronically stored
information, computer data, computer discs, computer chips, files, bulletins, reviews,
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compilations, sound recordings, films, photographs, videotapes, digital recordings, notes,
calendars, appointment books, diaries, time-sheets, time logs, or papers, no matter how
described or denominated, and any drafts thereof and includes all items encompassed by
Federal Rule of Civil Procedure 34(a). Different versions of the same document, such as
different copies of a written record bearing different handwritten notations, are different
documents within the meaning of the term as used. In case originals or original non-
identical copies are not available, the term "DOCUMENT" includes copies of originals or
copies of non-identical copies as the case may be.
10. DOPING -- The term DOPING means the use of prohibited substances
or prohibited methods to increase athletic performance, including but not limited to EPO,
testosterone, corticosteroids, blood transfusions, and/or masking agents.
11. IDENTIFY -- The term IDENTIFY has the following meanings:
a. When used in reference to a natural person, it means to state his
full name; his last known residence; his present business address, business telephone
number, and business position; and, if applicable, his past position and/or affiliation with
any DEFENDANT or party to this lawsuit and the dates thereof.
b. When referring to corporate or other entities, it shall mean to set
forth: (a) the name; (b) present or last known address; (c) its principal place of business;
and (d) the form or manner of its organization. Once a corporation or other entity has
thus been identified, it shall be sufficient thereafter when identifying that corporation or
other entity to state its full name.
c. When used in reference to a COMMUNICATION, it means:
i) If such COMMUNICATION was oral, to IDENTIFY the
person speaking and the person spoken to, and to state the date and place
of the COMMUNICATION and its substance;
ii) if such COMMUNICATION was contained in a
DOCUMENT, to IDENTIFY the DOCUMENT.
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d. When used in reference to a DOCUMENT, it means to state the
type of DOCUMENT (e.g., letter, email, database, spreadsheet, etc.), describing it
sufficiently (date, author, recipient(s)) for purposes of a request to produce or subpoena
duces tecum. In lieu of identification of a DOCUMENT, the DOCUMENT may be
provided or made available for inspection and copying. If any such DOCUMENT was,
but is no longer in your possession, or subject to your control, please state what
disposition was made of it.
e. When used in reference to a written contract, it means to provide
the parties to the contract, the date of the contract, a description of the nature and dollar
value of the consideration exchanged by each party under the contract, and any
modifications thereto. If any such contract was, but is no longer in your possession, or
subject to your control, please state what disposition was made of it.
12. PERSON(S) -- The term "PERSON(S)" means any natural person,
corporation, proprietorship, partnership, joint venture, association, firm, or entity
recognized in law, and shall include the owners, officers, directors, agents, trustees,
parents, subsidiaries, affiliates, assigns, predecessors, and successors of such "person."
13. RELATED TO or RELATING TO -- The terms RELATED TO and
RELATING TO mean discuss, describe, refer to, substantiate, evidence, contradict, or
be in any way logically or factually connected to the matter discussed.
14. ROSS INVESTMENTS, INC. -- The term ROSS INVESTMENTS,
INC. means Thomas Weisel Investment Management, Inc., Ross Investments, Inc., and
any d/b/as thereof, along with any person or entity known to YOU to have acted or
purported to act on its behalf, including but not limited to employees, directors, officers,
representatives, attorneys, contractors, consultants, agents, owners, shareholders,
subsidiaries, branches, divisions, units, affiliates, assigns, and predecessors or successors
in interest.
15. SPONSORSHIP AGREEMENTS -- The term SPONSORSHIP
AGREEMENTS means the October 1, 1995 agreement AND/OR the January 1, 2001
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agreement between the U.S. POSTAL SERVICE AND TAILWIND, and any
modifications, amendments, extensions, exhibits, or novations to such agreements.
16. TAILWIND The term TAILWIND means Montgomery Sports, Inc.,
TWP Sports, Inc., Tailwind Sports, LLC, Tailwind Sports Corporation, Tailwind Sports
Corp., Tailwind Sports, Inc., Disson Furst and Partners, LLC, Disson Furst & Partners,
LLC, DFP Cycling, LLC, Tailwind Cycling, LLC and any other d/b/as of any of the
foregoing entities, along with any person or entity known to YOU to have acted or
purported to act on its behalf, including but not limited to employees, directors, officers,
in interest.
17. THOMAS WEISEL PARTNERS The term THOMAS WEISEL
PARTNERS means Thomas Weisel Partners, or any of its subsidiaries, affiliates or
related entities, including but not limited to Thomas Weisel Partners, LLP, Thomas
Weisel Partners, LLC, Thomas Weisel Partners Group, Inc., Thomas Weisel Global
Growth Partners, Thomas Weisel Capital Partners, Tailwind Capital, and Tailwind
Capital Partners.
18. UCI The term UCI means the Union Cycliste Internationale, along
with any person or entity known to YOU to have acted or purported to act on its behalf,
including but not limited to employees, directors, officers, representatives, attorneys,
contractors, consultants, agents, branches, divisions, units, assigns, and predecessors or
successors in interest.
19. U.S. INVESTIGATION The term U.S. INVESTIGATION means the
United States investigation RELATING TO DOPING by the USPS TEAM, including
any civil and criminal investigations undertaken by the United States, including but not
limited to the Department of Justice, the Internal Revenue Service, the Federal Bureau of
Investigation, the Food and Drug Administration, or the U.S. POSTAL SERVICE Office
of Inspector General.
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20. USADA The term USADA means the United States Anti-Doping
Agency, along with any person or entity known to YOU to have acted or purported to act
on its behalf, including but not limited to employees, directors, officers, representatives,
attorneys, contractors, consultants, agents, branches, divisions, units, assigns, and
predecessors or successors in interest.
21. USADA INVESTIGATION The term USADA INVESTIGATION
means USADAs investigation RELATING TO DOPING by the USPS TEAM.
22. U.S. POSTAL SERVICE The term U.S. POSTAL SERVICE means
the United States Postal Service, along with any person or entity known to YOU to have
acted or purported to act on its behalf, including but not limited to employees, directors,
officers, representatives, attorneys, contractors, consultants, agents, branches, divisions,
units, assigns, and predecessors or successors in interest.
23. USPS TEAM The term USPS TEAM means the professional cycling
team sponsored by the United States Postal Service, along with any person or entity
known to YOU to have acted or purported to act on its behalf, including but not limited to
employees, directors, officers, representatives, attorneys, contractors, consultants, agents,
owners, shareholders, assigns, and predecessors or successors in interest.
24. WADA The term WADA means the World Anti-Doping Agency,
along with any person or entity known to YOU to have acted or purported to act on its
behalf, including but not limited to employees, directors, officers, representatives,
attorneys, contractors, consultants, agents, branches, divisions, units, assigns, and
predecessors or successors in interest.
25. WRITTEN CONTRACT / ORAL CONTRACT - The term
WRITTEN CONTRACT means an agreement between parties, the terms of which
have been reduced to writing, including any modifications thereto. The term ORAL
CONTRACT means an agreement between parties that is either partly in writing and
partly dependent on spoken words or that is entirely dependent on spoken words,
including any modifications thereto.
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26. YOU / YOUR - The terms "YOU" or "YOUR" means the party to whom
discovery is addressed, along with any person or entity known by that party to have acted
or purported to act on the partys behalf, including but not limited to employees,
directors, officers, representatives, attorneys, contractors, consultants, agents, owners,
shareholders, subsidiaries, branches, divisions, units, affiliates, assigns, and predecessors
or successors in interest.
INSTRUCTIONS
1. In responding to these interrogatories, defendant is required to furnish all
documents and information that are available to defendant, not merely such documents
and information as the person(s) preparing the responses know of their own personal
knowledge, including information in the possession of defendant's attorneys, employees,
or other persons directly or indirectly employed by, or connected with defendant or
defendants attorneys or consultants, or anyone acting on defendant's behalf or otherwise
subject to defendant's control. In responding to these Interrogatories, defendant is
required to make a diligent search of defendants records and of other documents and
materials in his possession or the possession of defendants employees, attorneys,
consultants, or other representatives.
2. Each interrogatory shall be construed to include information within the
knowledge, possession or control of defendant, defendants attorneys, investigators,
agents, owners, subsidiaries, officers, employees, or other representatives of the
defendant and/or defendants attorneys, as of the date of the answers given to these
interrogatories and any supplemental information, knowledge, data, documents or
communication responsive to these interrogatories which is subsequently generated,
obtained or discovered.
3. If the response to any interrogatory consists in whole or in part of an
objection relating to or including burdensomeness, then with respect to such responses:
a. Provide such information as can be ascertained without undue
burden;
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b. State with particularity the basis for each such objection, including:
(i) a description of the process or method required to obtain
any fact responsive to the interrogatory; and
(ii) the estimated costs and time required to obtain any fact
responsive to the interrogatory;
c. Describe the nature and extent of the documents or other source(s),
if any, from which any fact responsive to the interrogatory can be obtained; and
d. State whether the documents or other sources will be made
available for inspection and copying.
4. If you claim privilege as a ground for not fully answering any
interrogatory, describe the factual basis for said claim of privilege in sufficient detail so
as to permit the court to adjudicate the validity of the claim. If the claim of privilege
relates to identification of any document (including any electronically stored
information), then state for each such document the following information:

a. The date of the document;
b. The type of document (e.g., letter, memorandum, note, etc.);
c. The number of pages of the document;
d. The author(s) of the document;
e. ALL recipients of the document (whether or not listed in the
document), including the address of each;
f. The subject matter of the document;
g. The number of each interrogatory to which the document is
responsive; and
h. The specific grounds for its non-production.
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5. If the response to any interrogatory consists, in whole or in part, of an
objection(s), state with specificity the full objection(s) and the particularized basis for
each said objection, and answer the interrogatory to the extent it is not subject to your
objection, including producing any responsive document(s) (including any electronically
stored information) not subject to your objection.
6. If an interrogatory calls for information which is known to exist but is in
documents not in the possession or control of defendant, please IDENTIFY the person(s)
who are, or are believed to be, in possession or control of such documents, and, if such
documents were previously in possession or control of the defendant, state what
disposition was made of the documents by defendant.
7. If, for any reason, any of the information requested in these interrogatories
or any documents, electronically stored information, objects, or tangible things to be
produced pursuant to these interrogatories have been destroyed, lost, overwritten, or
otherwise disposed of, please describe such information, documents, electronically stored
information, objects and/or tangible things and IDENTIFY for each category of
information or category of documents, electronically stored information, objects or
tangible things:
a. The date the information or document, electronically stored
information, object or tangible thing was lost, destroyed,
overwritten or disposed of;
b. ALL witnesses who have knowledge of the loss, destruction,
overwriting or disposal; and
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c. ALL documents which relate or refer to the loss, destruction,
overwriting, or disposal of the document, electronically stored
information, object or tangible thing.
d. An explanation for why the information or document,
electronically stored information, object or tangible thing was
destroyed, lost, overwritten, or otherwise disposed of.
8. All documents produced in response to an interrogatory contained herein
shall be segregated and labeled so as to identify to which interrogatory each such
produced document responds, and, as to format shall be produced in accordance with the
protocol agreed to by the parties in their Rule 26(f) Conference Report.
9. Unless otherwise stated, references in these requests to any business entity
include the business entity, along with any person or entity acting or purporting to act on
its behalf, including but not limited to employees, directors, officers, representatives,
attorneys, contractors, consultants, agents, owners, shareholders, subsidiaries, branches,
divisions, units, affiliates, assigns, and predecessors or successors in interest.
10. Unless otherwise indicated in a specific request, the time period covered
by each request is January 1, 1995 through the present.
11. Whenever an interrogatory includes a request for a date or time period, if
you cannot give the exact day, month and year, please give your best estimate thereof.
12. If YOU deem any definition, instruction or interrogatory to be in any way
ambiguous, please describe as part of your answer any matters or terms deemed
ambiguous and explain how you have interpreted the ambiguity in providing your
answer.
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13. These interrogatories are continuing in character so as to require you to
promptly amend or supplement your responses and any related document production if
you obtain or discover further information or documents (including any electronically
stored information) after providing your initial responses.
INTERROGATORIES
1. (a) IDENTIFY ALL PERSONS (including but not limited to the PERSONS
listed on Exhibit A) who YOU know or believe had knowledge, at ANY point
between January 1, 1995 and February 28, 2010, of DOPING by Lance
Armstrong or ANY rider on the USPS TEAM.
(b) For each PERSON listed in response to subpart (a), DESCRIBE ALL facts
which form the basis for YOUR knowledge or belief that the PERSON had such
knowledge of DOPING by Lance Armstrong or ANY rider on the USPS TEAM.
(c) For each PERSON listed in response to subpart (a), DESCRIBE ALL actions
taken by that PERSON to assist Lance Armstrong or ANY other rider on the
USPS TEAM with DOPING or concealing DOPING between January 1, 1995
and February 28, 2010.
2. IDENTIFY ALL written or oral statements (to the United States, to any other
DEFENDANT, to any sponsor of the USPS TEAM, to a member of the press, or
in public, in any legal proceeding, or under oath) by CSE, William Stapleton or
Barton Knaggs denying DOPING by Lance Armstrong or ANY other rider on the
USPS TEAM or by the USPS TEAM generally.
3. DESCRIBE ALL actions taken by YOU or ANY other DEFENDANT, between
January 1, 1995 and the present, to discourage or deter ANY individual from
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disclosing information or commenting publicly about DOPING by Lance
Armstrong or ANY other rider on the USPS TEAM.
4. DESCRIBE ALL actions taken by YOU or ANY other DEFENDANT, between
January 1, 1995 and December 31, 2004, to investigate or prevent DOPING by
Lance Armstrong or ANY other rider on the USPS TEAM.
5. IDENTIFY ALL current or former employees of the United States Government,
including but not limited to the U.S. POSTAL SERVICE, who YOU contend
knew or should have known, at ANY point prior to June 10, 2010, of DOPING by
Lance Armstrong or ANY other members of the USPS TEAM while they rode for
the team, including the basis for YOUR contention that each PERSON knew or
should have known of the conduct.
6. IDENTIFY ALL COMMUNICATIONS between YOU and Floyd Landis
between January 1, 2002 and the present RELATING TO DOPING or to financial
or contract matters.
7. IDENTIFY all PERSONS who disclosed the existence of this qui tam action or
discussed this qui tam action with any PERSON with whom communication
about this qui tam action was prohibited by the seal in this case, prior to the
Courts unsealing order on February 22, 2013.
8. IDENTIFY any DOCUMENTS that are relevant or potentially relevant to this
case that have been deleted, lost or destroyed, and for each and every
DOCUMENT that YOU IDENTIFY, state the type of DOCUMENT, its subject
matter, author and date and the circumstances in which it was deleted, lost or
destroyed.
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9. DESCRIBE each and every action YOU have taken, or directed be taken, to
locate, maintain or preserve DOCUMENTS that are relevant or potentially
relevant to this case, including all locations that YOU searched for such
DOCUMENTS (including hard copy les, servers, email systems, backup
systems, hard drives, optical disks, databases, cellphones, cloud services, voice
mail, third-party).
10. IDENTIFY ALL officers, directors and employees of the CSE RELATED
ENTITIES (with the exception of temporary staff working solely on music
events) whose services were terminated or constructively terminated by the CSE
RELATED ENTITIES.
11. List ALL board meetings of each of the CSE RELATED ENTITIES between
1995 and 2007.
Dated: July 2, 2014 ____________/s/________________
Paul D. Scott
pdscott@lopds.com

____________/s/________________
Lani Anne Remick
laremick@lopds.com
U.S.D.C. No. PA0045
Jon L. Praed
U.S.D.C. No. 450764
D.C. Bar No. 51665
Pier 9, Suite 100
Tel: (415) 981-1212
Fax: (415) 981-1215


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EXHIBIT A
Defendants
Johan Bruyneel
Thomas Weisel
Bill Stapleton
Bart Knaggs

Tailwind
Dan Osipow
Mark Gorski
Emma OReilly
Geert Duffeleer
Laurenzo Lapage
Edward 'Eddie B' Borysewicz
Johnny Weltz

Tailwind Board
Jody Gessow
Terry Lee
Joe Vittoria,
Cindy Disson,
Allen Furst
Harvey Schiller
John Bucksbaum
John Burke
Ward Woods
Kenneth Barnett

Armstrong
Chris Carmichael
Michele Ferrari
Kristin Armstrong
Sheryl Crow
Stephanie McIlvain
Mark Higgins
Mike Anderson
Attorneys for Lance Armstrong (including Tim Herman, Sean Breen, Bryan Daly,
Robert Luskin, Matthew Himsworth, Donald Manasse, Christina Charrier, Bournazel,
John Keker, Elliot Peters, Sharif Jacobs, Mark Fabiani)

Doping Experts
Edward Coyle
Don Caitlin

15

TWP
Boyd Fellows
Matthew Barger
Jim Ochowicz

CSE
Laura Hundley
Capital Sports and Entertainment Holdings, Inc.
Capital Sports and Entertainment, Inc.
Capital Sports Ventures,

Medical Personnel
Dr. Pedro Celaya
Dr. Luis Garcia del Moral
Jose Pepe Marti
Dr. Jose Aramendi
Dr. Dag Van Elsland
Dr. Herman Falsetti

UCI
Hein Verbruggen
Pat McQuaid
Emile Vrijman
Philippe Verbiest
Sylvia Shenk
Dr. Mario Zorzoli

USA Cycling
Steve Johnson
Jim Ochowicz
Jeff Garvey
Mike Plant
Matthew Barger
Gerard Bisceglia
David Tenner
Steve Hess

USA Cycling Foundation
Thomas Weisel
Lance Armstrong
Steve Johnson
David Williams
John Bucksbaum
Doug Ellis
Matthew Barger
16

Jeff Garvey
Mark Bissell
Tench Coxe
Champions Club
Robert L. Emery
Michael Patterson
Greg Penner
Matthew Barger
Boyd Fellows
Skip Battle
Jeff Garvey
Rich Silverstein
Mark Bissell
Peter Grauer
Bob Stapleton
Michael Brooks
Mick Heliman
S. R. Walton
John Bucksbaum
Russell Hirsch
Thomas Weisel
Richard Cashin
Jeff Jacobs
David Williams
Tench Coxe
Thomas Kempner
Benjamin Winslow
Andrew Davis
Terry Lee
Priscilla Woods
Bennett Dorrance
Ed McCall
Doug Ellis
Rafael Ortiz

USADA
Travis Tygart
William Bock

WADA
Dick Pound
John Fahey

Livestrong
Jeff Garvey
John Korioth
17

Richard Rosenblatt

Floyd Landis
Dr. Brent Kay
Dr. Arnie Baker
Wil Geoghegaan
Paul Scott

Riders
Betsy Andreu
Frankie Andreu
Christophe Bassons
Tyler Hamilton
Willy Voet
Greg Lemond
Cathy Lemond
Filippo Simeoni
Michael Barry
Levi Leipheimer
Steven Swart
Christian Vande Velde
Jonathan Vaughters
Dave Zabriskie

Journalists
David Walsh
Alan English
Paul Kimmage
Pierre Ballester
Reed Albergotti
Vanessa OConnell

Other
John Burke
Andrew Messick
Bjarne Riis
Andy Riis
Mark Holowesko

18

CERTIFICATE OF SERVICE BY EMAIL

I hereby certify that a true and correct copy of the foregoing RELATORS FIRST
SET OF INTERROGATORIES TO DEFENDANT CAPITAL SPORTS AND
ENTERTAINMENT HOLDINGS, INC. was served on this 2nd day of July 2014 on the
following counsel via electronic mail:

Counsel for Plaintiff the United States of America
Robert E. Chandler, Trial Attorney
U.S. Department of Justice
Commercial Litigation Branch
Civil Division, Fraud Section
P. O. Box 261
Ben Franklin Station
Washington, D.C. 20044
Robert.Chandler@usdoj.gov
David.M.Finkelstein@usdoj.gov

Darrell Valdez
Mercedeh Momeni
U.S. Attorney's Office
Judiciary Center Building
555 Fourth Street, NW
Mercedeh.Momeni@usdoj.gov
Darrell.Valdez@usdoj.gov

Counsel for Defendant Tailwind Sports Corporation
Blair G. Brown
Rachel Cotton
Zuckerman Spaeder LLP
1800 M Street, N. W., Suite 1000
Washington, DC 20036-5807
bbrown@zuckerman.com
rcotton@zuckerman.com

Counsel for Defendant Lance Armstrong
Robert Luskin
Benjamin Wood
SQUIRE PATTON BOGGS (US) LLP
2550 M Street, NW
robert.luskin@squirepb.com
benjamin.wood@squirepb.com

19

John Keker
Elliot R. Peters
R. James Slaughter
Sharif E. Jacob
Tia Alexander Sherringham
Keker & Van Nest LLP
633 Battery Street
San Francisco, CA 94111-1809
jkeker@kvn.com
epeters@kvn.com
rslaughter@kvn.com
sjacob@kvn.com
tsherringham@kvn.com

Counsel for Defendant J ohan Bruyneel
Thomas Zeno
Rebecca A. Worthington
1200 19th Street, N.W., Suite 300
rebecca.worthington@squirepb.com
thomas.zeno@squirepb.com

Other service for Defendant J ohan Bruyneel
Johan Bruyneel, c/o Mike Morgan
Lafone House, The Leathermarket,
Weston Street, SE1 3ER
mike.morgan@morgansl.com

Counsel for Defendants CSE, William Stapleton and Barton Knaggs
Marc S. Harris
Vicki Kirkland
Scheper Kim & Harris LLP
One Bunker Hill
Los Angeles, CA 90071
vkirkland@scheperkim.com

John Patrick Pierce
THEMIS PLLC
2305 Calvert Street, N.W.
jpierce@themis.us.com

20

Counsel for Defendants Thomas W. Weisel and Ross I nvestments, I nc.
Robert A. Sacks
Brendan Cullen
Christopher M. Viapiano
Sullivan & Cromwell LLP
1888 Century Park East
Los Angeles, California 90067-1725
sacksr@sullcrom.com
cullenb@sullcrom.com
viapianoc@sullcrom.com

/s/ .
Lani Anne Remick



EXHIBIT B

INTERROGATORIES


EXHIBIT C

INTERROGATORIES
1



UNITED STATES OF AMERICA
ex rel. FLOYD LANDIS,

Plaintiffs,

v.

et al.,

Defendants.
___________________________________
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No. 1:10-cv-00976-RLW

RELATORS FIRST SET OF REQUESTS FOR PRODUCTION OF
DOCUMENTS TO DEFENDANT WILLIAM STAPLETON

Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and Local
Civil Rule 26.2 of the Rules of the United States District Court for the District of
Columbia, relator Floyd Landis hereby requests that the above-named defendant respond
in writing within 30 days to the following First Set of Requests for Production and that
defendant make all responsive documents available for inspection and copying within 30
days at the Law Offices of Paul D. Scott, P.C., Pier 9, Suite 100, The Embarcadero, San
Francisco, CA 94111.
DEFINITIONS AND INSTRUCTIONS
These Requests for Production shall be interpreted and answered, and responsive
materials shall be produced, in accordance with the following Definitions and
Instructions.

2

DEFINITIONS
The following definitions, whether or not capitalized, shall apply to each Request below:
1. ALL -- The term ALL is intended to be construed in the broadest
possible manner so as to include, but not be limited to, each and every.
2. AND / OR -- The words "AND" and "OR" shall mean "and/or."
3. ANY -- The term ANY means one or more.
4. COMMUNICATION -- The term "COMMUNICATION" means a
transmittal of information, or request for information, by DOCUMENT or otherwise and
includes any conversation in person, by telephone or by any other means, as well as any
utterance heard by another person whether in person, by telephone or otherwise.
5. CSE -- The term CSE means Capital Sports and Entertainment
Holdings, Inc. and any d/b/as thereof, along with any person or entity acting or
purporting to act on its behalf, including but not limited to employees, directors, officers,
in interest.
6. CSE RELATED ENTITIES -- The term CSE RELATED ENTITIES
means CSE, Capital Sports Ventures, and Capital Sports & Entertainment, Inc.
7. DEFENDANTS -- The term DEFENDANTS means TAILWIND,
ROSS INVESTMENTS, INC., CSE, Lance Armstrong, J ohan Bruyneel, Thomas W.
Weisel, William J . Stapleton and Barton B. Knaggs.
8. DOCUMENT -- The term DOCUMENT refers to, means, and includes
all written or graphic matter or tangible things of every kind and description, however
produced or reproduced, in YOUR actual or constructive possession, custody, or control,
including but not limited to all originals (or copies where originals are unobtainable or
where the copies are not identical to the originals) of correspondence, emails,
memoranda, reports, applications, claims, policies of insurance, printed matter, contracts,
agreements, proposals, bids, work papers, statistical records, minutes, interoffice
3

communications, studies, technical data, charts, brochures, electronically stored
information, computer data, computer discs, computer chips, files, bulletins, reviews,
compilations, sound recordings, films, photographs, videotapes, digital recordings, notes,
calendars, appointment books, diaries, time-sheets, time logs, or papers, no matter how
described or denominated, and any drafts thereof and includes all items encompassed by
Federal Rule of Civil Procedure 34(a). Different versions of the same document, such as
different copies of a written record bearing different handwritten notations, are different
documents within the meaning of the term as used. In case originals or original non-
identical copies are not available, the term "DOCUMENT" includes copies of originals or
copies of non-identical copies as the case may be.
9. DOPING -- The term DOPING means the use of prohibited substances
or prohibited methods to increase athletic performance, including but not limited to EPO,
testosterone, corticosteroids, blood transfusions, and/or masking agents.
10. IDENTIFY -- The term IDENTIFY has the following meanings:
a. When used in reference to a natural person, it means to state his
full name; his last known residence; his present business address, business telephone
number, and business position; and, if applicable, his past position and/or affiliation with
any DEFENDANT or party to this lawsuit and the dates thereof.
b. When referring to corporate or other entities, it shall mean to set
forth: (a) the name; (b) present or last known address; (c) its principal place of business;
and (d) the form or manner of its organization. Once a corporation or other entity has
thus been identified, it shall be sufficient thereafter when identifying that corporation or
other entity to state its full name.
c. When used in reference to a COMMUNICATION, it means:
i) If such COMMUNICATION was oral, to IDENTIFY the
person speaking and the person spoken to, and to state the date and place
of the COMMUNICATION and its substance;
4

ii) if such COMMUNICATION was contained in a
DOCUMENT, to IDENTIFY the DOCUMENT.
d. When used in reference to a DOCUMENT, it means to state the
type of DOCUMENT (e.g., letter, email, database, spreadsheet, etc.), describing it
sufficiently (date, author, recipient(s)) for purposes of a request to produce or subpoena
duces tecum. In lieu of identification of a DOCUMENT, the DOCUMENT may be
provided or made available for inspection and copying. If any such DOCUMENT was,
but is no longer in your possession, or subject to your control, please state what
disposition was made of it.
e. When used in reference to a written contract, it means to provide
the parties to the contract, the date of the contract, a description of the nature and dollar
value of the consideration exchanged by each party under the contract, and any
modifications thereto. If any such contract was, but is no longer in your possession, or
subject to your control, please state what disposition was made of it.
11. RELATED TO or RELATING TO -- The terms RELATED TO and
RELATING TO mean discuss, describe, refer to, substantiate, evidence, contradict, or
be in any way logically or factually connected to the matter discussed.
12. ROSS INVESTMENTS, INC. -- The term ROSS INVESTMENTS,
INC. means Thomas Weisel Investment Management, Inc., Ross Investments, Inc., and
any d/b/as thereof, along with any person or entity acting or purporting to act on its
13. SPONSORSHIP AGREEMENTS -- The term SPONSORSHIP
AGREEMENTS means the October 1, 1995 agreement AND/OR the J anuary 1, 2001
agreement between the U.S. POSTAL SERVICE AND TAILWIND, and any
modifications, amendments, extensions, exhibits, or novations to such agreements.
5

14. TAILWIND The term TAILWIND means Montgomery Sports, Inc.,
TWP Sports, Inc., Tailwind Sports, LLC, Tailwind Sports Corporation, Tailwind Sports
Corp., Tailwind Sports, Inc., Disson Furst and Partners, LLC, Disson Furst & Partners,
LLC, DFP Cycling, LLC, Tailwind Cycling, LLC and any other d/b/as of any of the
foregoing entities, along with any person or entity acting or purporting to act on its
15. THOMAS WEISEL PARTNERS The term THOMAS WEISEL
PARTNERS means Thomas Weisel Partners, or any of its subsidiaries, affiliates or
related entities, including but not limited to Thomas Weisel Partners, LLP, Thomas
Weisel Partners, LLC, Thomas Weisel Partners Group, Inc., Thomas Weisel Global
Growth Partners, Thomas Weisel Capital Partners, Tailwind Capital, and Tailwind
Capital Partners.
16. UCI The term UCI means the Union Cycliste Internationale, along
with any person or entity acting or purporting to act on its behalf, including but not
limited to employees, directors, officers, representatives, attorneys, contractors,
consultants, agents, branches, divisions, units, assigns, and predecessors or successors in
interest.
17. U.S. INVESTIGATION The term U.S. INVESTIGATION means the
United States investigation RELATING TO DOPING by the USPS TEAM, including
any civil and criminal investigations undertaken by the United States, including but not
limited to the Department of J ustice, the Internal Revenue Service, the Federal Bureau of
Investigation, the Food and Drug Administration, or the U.S. POSTAL SERVICE Office
of Inspector General.
18. USADA The term USADA means the United States Anti-Doping
Agency, along with any person or entity acting or purporting to act on its behalf,
including but not limited to employees, directors, officers, representatives, attorneys,
6

contractors, consultants, agents, branches, divisions, units, assigns, and predecessors or
successors in interest.
19. USADA INVESTIGATION The term USADA INVESTIGATION
means USADAs investigation RELATING TO DOPING by the USPS TEAM.
20. U.S. POSTAL SERVICE The term U.S. POSTAL SERVICE means
the United States Postal Service, along with any person or entity acting or purporting to
act on its behalf, including but not limited to employees, directors, officers,
representatives, attorneys, contractors, consultants, agents, branches, divisions, units,
assigns, and predecessors or successors in interest.
21. USPS TEAM The term USPS TEAM means the professional cycling
team sponsored by the United States Postal Service, along with any person or entity
acting or purporting to act on its behalf, including but not limited to employees, directors,
officers, representatives, attorneys, contractors, consultants, agents, owners, shareholders,
assigns, and predecessors or successors in interest.
22. WADA The term WADA means the World Anti-Doping Agency,
along with any person or entity acting or purporting to act on its behalf, including but not
limited to employees, directors, officers, representatives, attorneys, contractors,
consultants, agents, branches, divisions, units, assigns, and predecessors or successors in
interest.
23. WRITTEN CONTRACT / ORAL CONTRACT - The term
WRITTEN CONTRACT means an agreement between parties, the terms of which
have been reduced to writing, including any modifications thereto. The term ORAL
CONTRACT means an agreement between parties that is either partly in writing and
partly dependent on spoken words or that is entirely dependent on spoken words,
including any modifications thereto.
24. YOU / YOUR - The terms "YOU" or "YOUR" means the party to whom
discovery is addressed, along with any person or entity acting or purporting to act on the
partys behalf, including but not limited to employees, directors, officers, representatives,
7

INSTRUCTIONS
1. In responding to these Requests for Production, defendant is
required to furnish all documents and information that are available to defendant, not
merely such documents and information as the person(s) preparing the responses
know of their own personal knowledge, including information in the possession of
defendant's attorneys, employees, or other persons directly or indirectly employed by, or
connected with defendant or defendants attorneys or consultants, or anyone acting on
defendant's behalf or otherwise subject to defendant's control. In responding to these
requests for production of documents, defendant is required to make a diligent search of
defendants records and of other documents and materials in his possession or the
possession of defendants employees, attorneys, consultants, or other representatives.
2. Please produce the originals and all copies thereof if any copy is other
than identical to the original, in the order called for in the categories listed below,
identified by the category to which each document belongs, or, if applicable, in the
manner kept in the ordinary course of business.
3. All documents shall be produced with all associated organizational
information as kept in the ordinary course of business, such as file folders, dividers, and
file labels. All documents which are responsive in whole or in part to any request shall
be produced in full, including any appendices, attachments, and similar items.
4. Electronically Stored Information (ESI) shall be produced in accordance
with the protocol agreed to by the parties. Any documents produced in paper form shall
be Bates-numbered sequentially.

5. If any document (including any electronically stored information)
responsive to this request is withheld from production, then state for each such document
the following information, in a log produced on the response date:
8

a. The date of the document;
b. The type of document (e.g., letter, memorandum, note, etc.);
c. The number of pages of the document;
d. The author(s) of the document;
e. ALL recipients of the document (whether or not listed in the
document), including the address of each;
f. The subject matter of the document;
g. The number of each request to which the document is responsive;
and
h. The specific grounds for its non-production.
6. If the response to any request consists, in whole or in part, of an
objection(s), state with specificity the full objection(s) and the particularized basis for
each said objection, and produce any responsive document(s) (including any
electronically stored information) not subject to your objection.
7. If, for any reason, any of the documents, electronically stored information,
objects, or tangible things to be produced pursuant to this request have been destroyed,
lost, overwritten, or otherwise disposed of, please describe such documents,
electronically stored information, objects or tangible things and IDENTIFY for each
category of documents, electronically stored information, objects or tangible things:
a. The date the document, electronically stored information, object or
tangible thing was lost, destroyed, overwritten or disposed of;
b. ALL witnesses who have knowledge of the loss, destruction,
overwriting or disposal; and
9

c. ALL documents which relate or refer to the loss, destruction,
overwriting, or disposal of the document, electronically stored
information, object or tangible thing.
d. An explanation for why the information was destroyed, lost,
overwritten, or otherwise disposed of.
8. If you do not have any documents responsive to a request, your response
to that request should state that you do not have any responsive documents.
9. Unless otherwise stated, references in these requests to any business entity
include the business entity, along with any person or entity acting or purporting to act on
its behalf, including but not limited to employees, directors, officers, representatives,
10. Unless otherwise indicated in a specific request, the time period covered
by each request is J anuary 1, 1995 through the present.
11. These requests are continuing in character so as to require you to promptly
amend or supplement your responses and your production if you obtain or discover
further documents (including any electronically stored information) after providing our
initial responses.

REQUESTS FOR PRODUCTION
1. ALL DOCUMENTS YOU have provided in response to the U.S.
INVESTIGATION, including, but not limited to, any DOCUMENTS YOU have
provided in response to any subpoena or other request for DOCUMENTS, in the
same format as provided to the United States, and with the same Bates numbering
or any other numbering, if applicable.

10

2. ALL DOCUMENTS YOU have provided to USADA RELATING TO the
USADA INVESTIGATION, in the same format as provided to USADA, and with
the same Bates numbering or any other numbering, if applicable.

3. ALL DOCUMENTS YOU have provided to UCI RELATING TO any
investigation or inquiry by UCI, in the same format as provided to UCI, and with
the same Bates numbering or any other numbering, if applicable.

4. ALL DOCUMENTS YOU have provided in connection with any investigation or
inquiry into DOPING by any entity or person - other than the United States,
USADA, or UCI - in the same format as provided to such entity or person, and
with the same Bates numbering or any other numbering, if applicable.

5. ALL of your responses to discovery in any civil or administrative proceeding
RELATING TO allegations of DOPING by Armstrong or the USPS TEAM.

6. ALL COMMUNICATIONS RELATING TO any inquiry or investigation
RELATING TO Lance Armstrong or the USPS TEAM by the United States,
USADA, USA Cycling or UCI.

7. ALL COMMUNICATIONS between YOU and any other person or entity
RELATING TO any investigation of DOPING in cycling, including, but not
limited to, the following: the U.S. INVESTIGATION; the USADA
INVESTIGATION; any investigation or inquiry associated with the UCI or any
related commission or organization; the French investigation into the use of
Actovegin by the USPS Team in 2000; the Italian criminal investigation into
Michelle Ferrari; the investigation into LEquipes allegations in 2005 that Lance
Armstrong used EPO during the 1999 Tour De France; the Festina affair in 1998;
and Operation Puerto in 2006.

8. ALL COMMUNICATIONS between YOU and any person or entity RELATING
TO any allegations in books, news articles or other media outlets regarding
DOPING by Lance Armstrong or the USPS Team.

9. ALL DOCUMENTS RELATING TO the U.S. INVESTIGATION, the USADA
INVESTIGATION, DOPING, or this case.

10. ALL COMMUNICATIONS or DOCUMENTS RELATING TO any alleged
failure by Lance Armstrong or any other rider on the USPS TEAM to comply
with testing for DOPING or evading testing for DOPING.

11. ALL DOCUMENTS and COMMUNICATIONS RELATING TO denials of
DOPING by TAILWIND, the USPS TEAM or any of the riders on the team.

11

12. ALL DOCUMENTS RELATING TO any positive, potentially positive, or
abnormal test results for DOPING by Lance Armstrong or any other rider on the
USPS TEAM.

13. ALL COMMUNICATIONS preserved on an audio or video recording, in which
any part of the COMMUNICATION relates to DOPING.

14. ALL WRITTEN CONTRACTS of any type between YOU, or any entity
controlled by YOU, and any of the other DEFENDANTS.

15. ALL WRITTEN CONTRACTS between Lance Armstrong and any entity other
than TAILWIND which operated a cycling team.

16. ALL WRITTEN CONTRACTS, which referred to or RELATED TO the USPS
TEAM, Lance Armstrong or cycling, between any person or entity who was a
sponsor of the USPS TEAM and any of the following: TAILWIND, ANY OF
THE CSE RELATED ENTITIES, Tailwind Capital Partners, THOMAS WEISEL
PARTNERS, ROSS INVESTMENTS, Thomas Weisel, Livestrong, J ohan
Bruyneel, YOU or Bart Knaggs.

17. ALL COMMUNICATIONS and DOCUMENTS RELATING TO Lance
Armstrongs rider contracts with TAILWIND.

18. ALL DOCUMENTS RELATING TO the SPONSORSHIP AGREEMENTS,
including, but not limited to, all executed copies, drafts, amendments, novations,
modifications, extensions, exhibits thereto, and any correspondence or other
COMMUNICATIONS relating thereto.

19. ALL of TAILWINDs WRITTEN CONTRACTS with any entities other than the
U.S. POSTAL SERVICE RELATING TO sponsorship of the USPS TEAM,
including, but not limited to, executed copies of such agreements.

20. ALL WRITTEN CONTRACTS of TAILWIND, or any rider on the USPS
TEAM, or any sponsor of the USPS TEAM which contain a morals clause or a
reference to DOPING, including, but not limited do, any sponsorship or
promotion agreements.

21. ALL WRITTEN CONTRACTS between TAILWIND and its riders.

22. ALL DOCUMENTS RELATING to any cancellations of, or any other changes
to, any sponsor agreement RELATING TO DOPING by Lance Armstrong or
DOPING by any other rider for TAILWIND.

23. ALL DOCUMENTS or COMMUNICATIONS RELATING TO claims for
payment to the U.S. POSTAL SERVICE under the SPONSORSHIP
12

AGREEMENTS, including but not limited to claims for payment for services
provided by CSE, Knaggs, or YOU.

24. ALL DOCUMENTS RELATING TO TAILWINDs receipt of payments from
the U.S. POSTAL SERVICE under the SPONSORSHIP AGREEMENTS.

25. ALL articles of incorporation, amended articles of incorporation, articles of
organization, amended articles of organization, operating agreements, bylaws,
amended bylaws, and shareholder registers of TAILWIND from 1987 through
December 31, 2007.

26. ALL filings with any state government entity or the Securities and Exchange
Commission by TAILWIND from 1987 through the present.

27. The DOCUMENTS used to accomplish the sale of TAILWINDs shares to its
shareholders or partners.

28. ALL DOCUMENTS RELATING TO the sale of TAILWIND shares to YOU.

29. ALL DOCUMENTS RELATING TO the sale of TAILWIND shares to Thomas
Weisel, J ohan Bruyneel, Lance Armstrong, Bart Knaggs, or CSE.

30. DOCUMENTS sufficient to show the ownership interests in TAILWIND from
1987 through the date of its dissolution.

31. DOCUMENTS that show the officers, directors, employees and agents of
TAILWIND from 1987 through the present.

32. ALL DOCUMENTS that show the ownership interests in THOMAS WEISEL
PARTNERS held by any shareholder, officer, director, employee or agent of
TAILWIND, from J anuary 1, 1999 through the present.

33. ALL DOCUMENTS that show the ownership interests in Montgomery Securities
held by any shareholder, officer, director or employee of TAILWIND, from 1987
through the date Montgomery Securities ceased to exist.

34. ALL board minutes of TAILWIND from J anuary 1, 1987 through December 31,
2007.

35. ALL DOCUMENTS showing what the assets of Tailwind Sports Corporation
were upon its dissolution and how such assets were distributed.

36. ALL annual or other periodic financial statements (including balance sheets and
profit and loss statements) for TAILWIND from 1995 through the present.

13

37. ALL Private Placement Memoranda issued by TAILWIND from 1995 through
the present.

38. TAILWINDs federal and state income tax returns from 1995 through the present.

39. The General Ledger(s) or any other accounting records showing the funds flowing
into and out of TAILWIND from 1995 through 2007.

40. ALL DOCUMENTS and COMMUNICATIONS RELATING to the
capitalization or undercapitalization of TAILWIND.

41. ALL DOCUMENTS RELATING TO the dissolution of TAILWIND and the
distribution of its assets to shareholders.

42. ALL DOCUMENTS used to accomplish the sale of stock of Montgomery Sports,
Inc. by Montgomery Securities to Thomas Weisel or any entity affiliated with
him.

43. ALL DOCUMENTS used to accomplish the sale of stock of Montgomery Sports,
Inc. to Tailwind Sports, LLC.

44. ALL DOCUMENTS used to accomplish the merger of Tailwind Sports, LLC into
Tailwind Sports Corporation.

45. ALL DOCUMENTS RELATING TO payments by others (including, but not
limited to, Thomas Weisel) for the debts or expenses or any other obligation of
TAILWIND.

46. ALL DOCUMENTS RELATING TO diversion of TAILWINDs funds or assets
to non-corporate uses, including but not limited to the following: payments for
non-business related expenses to shareholders, officers, directors, employees or
their families or any business entities in which they held an interest.

47. ALL DOCUMENTS showing any payments or transfers of funds from Thomas
Weisel, or THOMAS WEISEL PARTNERS, or any account controlled in whole
or in part by Thomas Weisel, to YOU, J ohan Bruyneel, Lance Armstrong, or to
any other rider on the USPS TEAM.

48. ALL DOCUMENTS RELATING TO any loans by Thomas Weisel or THOMAS
WEISEL PARTNERS to TAILWIND, YOU, J ohan Bruyneel, Lance Armstrong,
or any rider on the USPS TEAM.

49. ALL DOCUMENTS showing any payments or transfers of funds from Thomas
Weisel or THOMAS WEISEL PARTNERS, or any account controlled in whole
or in part by Thomas Weisel, to TAILWIND.

14

50. ANY DOCUMENTS showing the location of TAILWINDs office space between
1995 and 2007, including but not limited to any space occupied by TAILWIND in
the offices of Montgomery Securities or Thomas Weisel Partners.

51. ALL DOCUMENTS RELATING TO the value of and/or the price paid for any
office space occupied by TAILWIND at Montgomery Securities or Thomas
Weisel Partners, including, but not limited to, any lease documents or other
DOCUMENTS which show the rental rates for such space from one year prior to
the date that TAILWIND occupied the space to one year after TAILWIND
vacated the space.

52. ALL DOCUMENTS or COMMUNICATIONS RELATING TO any funds
deposited with THOMAS WEISEL PARTNERS or Robert W. Baird by Hein
Verbruggen, by any entity owned or controlled by Hein Verbruggen, or by any
relative of Hein Verbruggen.

53. ALL DOCUMENTS or COMMUNICATIONS RELATING TO any funds
managed by or deposited with THOMAS WEISEL PARTNERS for the benefit of
any individual currently or formerly affiliated with UCI or USA CYCLING (or
for any entity which such individual owns or controls).

54. ALL DOCUMENTS or COMMUNICATIONS RELATING TO payments by
Thomas Weisel or THOMAS WEISEL PARTNERS to the UCI OR any person
affiliated with the UCI.

55. ALL DOCUMENTS RELATING TO Thomas Weisels change in position from
President to Chairman of TAILWIND.

56. ALL DOCUMENTS RELATING TO the transaction or decision by which CSE,
YOU or Bart Knaggs took on management responsibilities at TAILWIND.

57. ALL COMMUNICATIONS RELATING TO the transaction or decision by
which CSE, YOU or Bart Knaggs took on management responsibilities at
TAILWIND.

58. ALL DOCUMENTS RELATING TO any DEFENDANTs involvement in the
submission of claims for payment to, or the receipt of payments from, the U.S.
POSTAL SERVICE.

59. ALL DOCUMENTS showing whether claims for payments were copied to any
DEFENDANT or showing they were otherwise made aware of any claim for
payment submitted by TAILWIND to the U.S. POSTAL SERVICE.

60. ALL DOCUMENTS showing whether any DEFENDANT received copies of the
SPONSORSHIP AGREEMENTS or was made aware of the terms thereof.

15

61. ALL DOCUMENTS showing whether any DEFENDANT was aware of any
positive or inconclusive DOPING testing results by any rider on the USPS TEAM

62. ALL DOCUMENTS showing whether any DEFENDANT was copied on or was
otherwise made aware of the terms of Lance Armstrongs rider contract, or the
rider contract of any rider on the USPS TEAM.

63. ALL DOCUMENTS RELATING TO ANY DEFENDANTS contention that the
United States or the U.S. POSTAL SERVICE knew or should have known of
DOPING on the USPS TEAM.

64. ALL DOCUMENTS RELATING TO THE response of the UNITED STATES to
allegations of DOPING by Lance Armstrong or any other rider on the USPS
TEAM.

65. ALL DOCUMENTS RELATING TO the value of what the U.S. POSTAL
SERVICE received under the SPONSORSHIP AGREEMENTS, including but
not limited to any valuations, audits, or marketing analyses.

66. ALL DOCUMENTS RELATING TO the damages suffered by the U.S. POSTAL
SERVICE as a result of DOPING by the USPS TEAM, Lance Armstrong, or any
other member of the USPS TEAM.

67. ALL DOCUMENTS RELATING TO any contention that the U.S. POSTAL
SERVICE was not damaged as a result of DOPING by the USPS TEAM, Lance
Armstrong, or any other member of the USPS TEAM.

68. ALL DOCUMENTS OR COMMUNICATIONS RELATING TO Floyd Landis.

69. ALL DOCUMENTS that contradict the allegations of the United States or the
relator in this case.

70. ALL DOCUMENTS upon which YOU rely to deny the allegations of the United
States or the relator in their respective complaints against YOU in this case.

71. ALL DOCUMENTS OR COMMUNICATIONS RELATING TO this case.

72. ALL COMMUNICATIONS RELATING TO DOPING, the U.S.
INVESTIGATION, the USADA INVESTIGATION, or this case with any
persons affiliated with the news media as well as any DOCUMENTS related
thereto.

73. ALL DOCUMENTS that YOU may use to support any affirmative defenses YOU
have against the allegations of the United States or the relator in this case.

16

74. ALL privilege logs RELATING TO the U.S. INVESTIGATION, the USADA
INVESTIGATION, or any claims or litigation against YOU RELATING TO
DOPING.

75. ALL COMMUNICATIONS and DOCUMENTS relating to any investigation
YOU have conducted relating to the U.S. INVESTIGATION, the USADA
INVESTIGATION, or this case, including, but not limited to, any video-taping,
audio recording, or any other forms of surveillance or background investigation.

76. ALL DOCUMENTS or COMMUNICATIONS RELATING TO ANY statements,
transcripts, declarations, interviews or summaries of interviews of any persons
RELATING TO the U.S. INVESTIGATION, the USADA INVESTIGATION, or
this case.

77. ALL contracts between any YOU, on the one hand, and any of the CSE
RELATED ENTITIES, on the other hand.

78. ALL DOCUMENTS that describe the nature of the services YOU or any of the
CSE RELATED ENTITIES have provided for Lance Armstrong from 1995
through the present.

79. ALL DOCUMENTS establishing or evidencing an attorney-client relationship
between YOU OR the CSE RELATED ENTITIES, on the one hand, AND Lance
Armstrong, on the other, at any point between 1995 and the present.

80. ALL DOCUMENTS evidencing the lack of an attorney-client relationship
between YOU OR the CSE RELATED ENTITIES, on the one hand, and Lance
Armstrong, on the other, at any point between 1995 and the present.

81. ALL DOCUMENTS RELATING TO YOUR authorization or lack of
authorization to practice law at any point between 1995 and the present.

82. ALL DOCUMENTS RELATING TO Lance Armstrongs knowledge or lack
thereof that YOU were inactive or unauthorized to practice law at any point
between 1995 and the present.

83. ALL COMMUNICATIONS RELATING TO whether or not YOU were acting as
Lance Armstrongs attorney.

84. ALL contracts between YOU or any of the CSE RELATED ENTITIES, on the
one hand, and Lance Armstrong, on the other, including, but not limited to, any
engagement letters, retainer agreements, or other agreements describing any
services to be provided to Lance Armstrong.

85. ALL articles of incorporation, amended articles of incorporation, bylaws,
amended bylaws, and shareholder registers of the CSE RELATED ENTITIES.
17

86. ALL filings with the California Secretary of State, the Delaware Secretary of
State, or the Securities and Exchange Commission by the CSE RELATED
ENTITIES from 1995 through the present.

87. DOCUMENTS that list the breakdown in ownership of the CSE RELATED
ENTITIES at ANY or ALL points from 1995 through the present.

88. DOCUMENTS that list the officers, directors, employees and agents of the CSE
RELATED ENTITIES at any or all points from 1995 through the present.

89. ALL board minutes from 1995 through the present of CSE.

90. ALL COMMUNICATIONS between YOU and ANY of the following people or
entities:

a. Lance Armstrong
b. J ohan Bruyneel
c. Thomas Weisel
d. Barton Knaggs
e. the United States Postal Service or any current or former employee or
agent of the United States Postal Service
f. Thomas Weisel Partners
g. Mark Gorski
h. Dan Osipow
i. J im Ochowicz
j. Emma OReilly
k. Geert Duffeleer
l. Laurenzo Lapage
m. Edward 'Eddie B' Borysewicz
n. J ohnny Weltz
o. Stephanie McIlvain
p. Laura Hundley
q. Dr. Pedro Celaya
r. Dr. Luis Garcia del Moral
s. Dr. Michele Ferrari
t. Dr. J ose Aramendi
u. Dr. Dag Van Elsland
v. Dr. Eufemeniano Fuentes
w. Dr. Herman Falsetti
x. J ose Pepe Marti
y. Philippe Maire
z. Hein Verbruggen
aa. Pat McQuaid
bb. Emile Vrijman
cc. Philippe Verbiest
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dd. Sylvia Shenk
ee. Dr. Mario Zorzoli
ff. Steve J ohnson
gg. Floyd Landis

91. ALL DOCUMENTS RELATING TO payments to J ohan Bruyneel or to J ohan
Bruyneel Sports Management by TAILWIND or by any other DEFENDANT from
1999 through the present.

92. ALL DOCUMENTS RELATING TO any books RELATING TO cycling or
DOPING, including any drafts or final copies of such books and any
COMMUNICATIONS RELATING TO such books.

93. ALL DOCUMENTS YOU IDENTIFY in your Initial Disclosure pursuant to Rule
26(a)(1) of the Federal Rules of Civil Procedure.

94. ALL DOCUMENTS YOU IDENTIFY in response to ANY interrogatories in this
case.

Dated: J anuary 28, 2014 ____________/s/________________
Paul D. Scott
pdscott@lopds.com

____________/s/________________
Lani Anne Remick
laremick@lopds.com
U.S.D.C. No. PA0045
J on L. Praed
U.S.D.C. No. 450764
D.C. Bar No. 51665
Pier 9, Suite 100
Tel: (415) 981-1212
Fax: (415) 981-1215

CERTIFICATE OF SERVICE BY EMAIL

I hereby certify that a true and correct copy of the foregoing RELATORS FIRST
SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT
WILLIAM STAPLETON was served on this 28th day of January 2014 on the following
counsel via electronic mail:

Robert E. Chandler
David M. Finkelstein
Commercial Litigation Branch
Civil Division
P. O. Box 261
601 D Street
Robert.Chandler@usdoj.gov
David.M.Finkelstein@usdoj.gov
Matthew.C.Golojuch@usdoj.gov

Darrell Valdez
Mercedeh Momeni
U.S. Attorney's Office
Judiciary Center Building
Mercedeh.Momeni@usdoj.gov
Darrell.Valdez@usdoj.gov

Blair G. Brown
Rachel Cotton
Zuckerman Spaeder LLP
1800 M Street, N. W., Suite 1000
Washington, DC 20036-5807
bbrown@Zuckerman.com
rcotton@Zuckerman.com
njidun@zuckerman.com

Robert Luskin
Patton Boggs LLP
2550 M Street, NW
rluskin@pattonboggs.com

John Keker
Elliot R. Peters
R. James Slaughter
Sharif E. Jacob
Tia Alexander Sherringham
Keker & Van Nest LLP
633 Battery Street
San Francisco, CA 94111-1809
JKeker@kvn.com
EPeters@kvn.com
RSlaughter@kvn.com
SJacob@kvn.com
Tsherringham@kvn.com
APicar@kvn.com
KBringola@kvn.com
LHartz-Lewis@kvn.com
efiling@kvn.com

Robert A. Sacks
Brendan Cullen
Sullivan & Cromwell LLP
Los Angeles, California 90067-1725
sacksr@sullcrom.com
pannattonit@sullcrom.com

John Patrick Pierce
THEMIS PLLC
2305 Calvert Street, NW
JPierce@themis.us.com


Marc S. Harris
Vicki Kirkland
Scheper Kim & Harris LLP
One Bunker Hill
Los Angeles, CA 90071
vkirkland@scheperkim.com
pdayton@scheperkim.com

Thomas Zeno
Rebecca A. Worthington
Squire Sanders (US) LLP
1200 19th Street, N.W., Suite 300
Rebecca.Worthington@squiresanders.com
Thomas.Zeno@squiresanders.com
Lauren.Kuley@squiresanders.com
Constance.Young@squiresanders.com

___________/s/__________________
Lani Anne Remick


EXHIBIT D

INTERROGATORIES

1
UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA ex rel.
FLOYD LANDIS,
Plaintiffs,
v.
et al.
Defendants.

Case No. 1:10-cv-00976-CRC

DEFENDANT WILLIAM J. STAPLETONS AMENDED RESPONSES
AND OBJECTIONS TO RELATORS FIRST SET OF
REQUESTS FOR PRODUCTION OF DOCUMENTS
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and Local
Civil Rule 26.2 of the Rules of the United States District Court for the District of Columbia,
Defendant William J. Stapleton (Stapleton) hereby serves his amended responses and
objections to Relators First Set of Requests for Production of Documents, dated January 28,
2014. (the Requests).
PRELIMINARY STATEMENT
1. Stapletons general objections (General Objections) to the Requests are set forth
below. The General Objections shall be deemed continuing and, to avoid the necessity of
restating in full each objection, the General Objections are incorporated in full within each
response where applicable as if fully set forth in such response. The assertion of additional,
specific objections to certain Requests shall not be construed as a waiver of any applicable
General Objection to such Request.
2. The following responses (Responses) are based on Stapletons knowledge,
information, and belief at this time, and are complete to the best of Stapletons knowledge at this
time. Furthermore, these Responses were prepared based on Stapletons good faith interpretation

2
and understanding of the Requests and are subject to correction for inadvertent errors or
omissions, if any.
3. Stapletons General Objections and any specific objection to the Requests do not
concede the admissibility, relevancy, originality, truth, accuracy, completeness, or authenticity of
any document produced by Stapleton. Stapleton reserves the right to challenge the relevancy,
competency, materiality, authenticity and admissibility of the information provided by Stapleton.
Moreover, Stapleton reserves the right to supplement or amend the Responses at any time prior
to trial or as otherwise permitted by applicable law, the Federal Rules of Civil Procedure or the
rules of this Court, but, except as provided in Rule 26(e) of the Federal Rules of Civil Procedure,
Stapleton assumes no obligation to voluntarily supplement or amend the Responses to reflect
information, evidence, documents, or things discovered following service of these Responses.
4. Stapletons Responses to each and every Request are without waiver or limitation
of his right to object on grounds of competency, relevancy, privilege, materiality, confidentiality,
authenticity, or admissibility of evidence for any purpose, or any other ground for objection to
the use of any information or documents provided or referred to in these Responses, in discovery
or in any proceeding, or at a trial of this or any other action. Stapletons Responses are made
solely for the purposes of this action, and for no other purpose, and are provided subject to that
limitation.
5. To the extent that any Request seeks documents that are also sought by or
identified pursuant to any other Request, Stapleton declines to produce or identify multiple
copies of such documents. Each document produced or identified pursuant to any Request is
also produced pursuant to every other Request to which it is or may be responsive. Any and all
documents will be produced at a mutually agreeable date and time only after sufficient time to
conduct a reasonable search and inquiry.

3
6. Stapletons Response to a particular Request to produce documents or provide
information is not an admission that any such documents or information exist. Where Stapleton
undertakes to conduct a reasonable search for responsive documents, Stapleton represents only
that Stapleton will produce subject to all objections raised herein or hereafter relevant, non-
objectionable, non-privileged documents that are responsive to the Requests and that are within
Stapletons possession, custody, or control, should any such documents or information be located
after a reasonable search.
7. Stapleton provides these Responses subject to all appropriate objections that may
be made later in this action, including, but not limited to, objections concerning competency,
relevancy, materiality, propriety, and admissibility, which would require the exclusion of any
information, document, or thing produced in response to the Requests. Stapleton reserves the
right to interpose any such objection at the time of a later deposition, hearing, or trial.
GENERAL OBJECTIONS
1. Stapleton objects to the Requests to the extent the Requests seek to impose any
obligation on Stapleton exceeding those imposed by applicable law, the Federal Rules of Civil
Procedure, or the rules of this Court. Stapleton will construe and respond to the Requests in
accordance with his obligations under the Federal Rules of Civil Procedure and the rules of this
Court.
2. Stapleton objects to the Requests to the extent the Requests seek documents and
information that are neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence.
3. Stapleton objects to the Requests to the extent the Requests assume facts that are
not in evidence or are subject to dispute. Stapletons response to any such Request is not

4
intended to be construed, and shall not be construed, to reflect Stapletons agreement to any such
assumed fact or facts.
4. Stapleton objects to the Requests to the extent the Requests seek documents or
information protected from disclosure by the attorney-client privilege, attorney work product
doctrine, or any other privilege or immunity. The inadvertent production of such documents and
information in response to these Request is not intended to waive nor shall be deemed to have
waived the attorney-client privilege, the protections of the attorney work product doctrine, or any
other applicable privilege or immunity.
5. Stapleton objects to the Requests to the extent the Requests are vague, ambiguous,
overly broad, unduly burdensome, or unreasonably duplicative, and to the extent that they seek
documents or information not relevant to Relators claims in this action.
6. Stapleton objects to the Requests to the extent the Requests are unreasonably
cumulative or duplicative.
7. Stapleton objects to the Requests to the extent the Requests seek private,
privileged, and confidential commercial, financial, and/or proprietary business information.
Documents containing any such information will only be produced subject to the protections of a
suitable confidentiality order.
8. Stapleton objects to the Requests to the extent the Requests purport to require
anything beyond a reasonable search for documents, including to the extent that they seek the
production of documents maintained on backup tapes or similar archived media, or in other
locations that are not readily accessible, on the ground that it would be unduly burdensome for
Stapleton to search for and produce such documents. In responding to the Requests, Stapleton
will search to the extent he has not already done so his files covering a reasonable time
period and, where appropriate, using reasonable search terms.

5
9. Stapleton objects to the Requests to the extent they call for the production of
materials that are publicly available, already in Relators possession, equally available to
Stapleton and Relator, or obtained by Relator from other sources that can provide them more
easily or with less burden or expense than Stapleton.
10. Stapleton objects to the Requests to the extent the Requests seek information or
documents already in the possession of Relator or to which Relator has or had access.
11. Stapleton objects to the Requests to the extent that they seek the production of
documents that are not currently within his possession, custody, or control. Without limiting the
foregoing objection, Stapleton objects to the Requests to the extent the Requests seek documents
in the possession, custody, or control of his attorneys, advisors, agents, representatives,
employees, or other person or entities acting on his behalf or under his control.
Amended General Objection 11: Without limiting the foregoing objection, Stapleton
objects to the Requests to the extent the Requests seek documents in the possession, custody, or
control of his attorneys, advisors, agents, representatives, employees, or other persons or entities
acting on his behalf or under his control, except to the extent the documents in the possession,
custody, or control of such third parties are also in Knaggs possession, custody, or control as
defined by applicable law.
12. Stapleton objects to the Requests on the grounds of burden and undue expense
based on the excessive number of requests.
13. Stapleton objects to the definition of the term CSE on the grounds that it is
overly broad, vague, and ambiguous, and would make compliance with the Requests unduly
burdensome. For purposes of these Responses, Stapleton understands that the term CSE refers
to Capital Sports & Entertainment Holdings, Inc. and any d/b/a thereof. (CSE DEFINITION
OBJECTION)

6
Amended General Objection 13: Stapleton objects to the definition of the term CSE on
the grounds that it is overly broad, vague, ambiguous, and would make compliance with the
Requests unduly burdensome. For purposes of these Responses, Stapleton understands that the
term CSE refers to CSE, any d/b/a thereof, and individuals or other entities known to Stapleton
to have acted or purported to act on behalf of such entities. (CSE DEFINITION OBJECTION)
14. Stapleton objects to the definition of the term CSE RELATED ENTITIES on
the grounds that it is overly broad, vague, and ambiguous, and would make compliance with the
Requests unduly burdensome to the extent it incorporates the objectionable definition of the term
CSE. For purposes of these Responses, Stapleton understands that the term CSE RELATED
ENTITIES refers to Capital Sports & Entertainment Holdings, Inc., Capital Sports and
Entertainment, Inc., and Capital Sports Ventures. (CSE RELATED ENTITIES DEFINITION
OBJECTION)
15. Stapleton objects to the definition of the term DOPING on the grounds that it is
burdensome. For purposes of these Responses, Stapleton understands that the term DOPING
refers to the use of prohibited substances or prohibited methods to increase performance in
bicycle racing. (DOPING DEFINITION OBJECTION)
Amended Definition of DOPING: Pursuant to the parties meet and confer discussions,
the term DOPING refers to the use of prohibited substances or prohibited methods to increase
performance in professional bicycle racing and includes the use of EPO, testosterone,
corticosteroid, blood transfusions, and/or masking agents. Stapleton does not object to the
definition of DOPING, as amended.
16. Stapleton objects to the definition of the term IDENTIFY to the extent that it
purports to impose obligations on Stapleton that are not required under Rules 26 or 34 of the

7
Federal Rules of Civil Procedure or Local Civil Rule 26.2 of the rules of this Court.
(IDENTIFY DEFINITION OBJECTION)
17. Stapleton objects to the definition of the term ROSS INVESTMENTS, INC. on
the grounds that it is overly broad, vague, and ambiguous, and would make compliance with the
term ROSS INVESTMENTS, INC. refers to Thomas Weisel Investment Management, Inc.,
Ross Investments, Inc., and any d/b/a thereof. (ROSS INVESTMENTS, INC. DEFINITION
OBJECTION)
Amended General Objection 17: Stapleton objects to the definition of the term ROSS
INVESTMENTS, INC. on the grounds that it is overly broad, vague, ambiguous, and would
make compliance with the Requests unduly burdensome. For purposes of these Responses,
Stapleton understands that the term ROSS INVESTMENTS, INC. refers to Ross Investments,
Inc., any d/b/a thereof, and individuals or other entities known to Stapleton to have acted or
purported to act on behalf of such entities. (ROSS INVESTMENTS, INC. DEFINITION
OBJECTION)
18. Stapleton objects to the definition of the term TAILWIND on the grounds that
it is overly broad, vague, and ambiguous, and would make compliance with the Requests unduly
burdensome. For purposes of these Responses, Stapleton understands that the term
TAILWIND refers to Montgomery Sports, Inc.; TWP Sports, Inc.; Tailwind Sports, LLC;
Tailwind Sports Corporation; Tailwind Sports Corp.; Tailwind Sports, Inc.; Disson Furst and
Partners, LLC; Disson Furst & Partners, LLC; DFP Cycling, LLC; Tailwind Cycling, LLC; and
any d/b/a thereof. (TAILWIND DEFINITION OBJECTION)
Amended General Objection 18: Stapleton objects to the definition of the term
TAILWIND on the grounds that it is overly broad, vague, ambiguous, and would make

8
compliance with the Requests unduly burdensome. For purposes of these Responses, Stapleton
understands that the term TAILWIND refers to Tailwind, any d/b/a thereof, and individuals or
other entities known to Stapleton to have acted or purported to act on behalf of such entities.
(TAILWIND DEFINITION OBJECTION)
19. Stapleton objects to the definition of the term THOMAS WEISEL PARTNERS
on the grounds that it is overly broad, vague, and ambiguous, and would make compliance with
the Requests unduly burdensome. For purposes of these Responses, Stapleton understands that
the term THOMAS WEISEL PARTNERS refers to Thomas Weisel Partners, LLP; Thomas
Weisel Partners, LLC; Thomas Weisel Partners Group, Inc.; Thomas Weisel Global Growth
Partners; Thomas Weisel Capital Partners; Tailwind Capital; and Tailwind Capital Partners; and
any d/b/a thereof. (THOMAS WEISEL PARTNERS DEFINITION OBJECTION)
20. Stapleton objects to the definition of the term UCI on the grounds that it is
burdensome. For purposes of these Responses, Stapleton understands that the term UCI refers
to the Union Cycliste Internationale. (UCI DEFINITION OBJECTION)
Amended General Objection 20: Stapleton objects to the definition of the term UCI on
term UCI refers to UCI, any d/b/a thereof, and individuals or other entities known to Stapleton to
have acted or purported to act on behalf of such entities. (UCI DEFINITION OBJECTION)
21. Stapleton objects to the definition of the term U.S. INVESTIGATION on the
grounds that it is overly broad, vague, and ambiguous, and would make compliance with the
term U.S. INVESTIGATION refers to the investigation of Relators claims and allegations by

9
the U.S. Department of Justice and the U.S. Postal Service Office of the Inspector General
during the 2010 to 2013 period and the investigation of Lance Armstrong by the U.S. Attorneys
Office for the Central District of California during the 2010 to 2012 period. (U.S.
INVESTIGATION DEFINITION OBJECTION)
22. Stapleton objects to the definition of the term USADA on the grounds that it is
burdensome. For purposes of these Responses, Stapleton understands that the term USADA
refers to the United States Anti-Doping Agency. (USADA DEFINITION OBJECTION)
Amended General Objection 22: Stapleton objects to the definition of the term USADA
on the grounds that it is overly broad, vague, ambiguous, and would make compliance with the
term USADA refers to USADA, any d/b/a thereof, and individuals or other entities known to
Stapleton to have acted or purported to act on behalf of such entities. (USADA DEFINITION
OBJECTION)
23. Stapleton objects to the definition of the term USADA INVESTIGATION on
the grounds that is overly broad, vague, and ambiguous, in particular because it contains no time
limitation or details concerning the purported investigators or particular subject matter of the
purported investigation. (USADA INVESTIGATION DEFINITION OBJECTION)
24. Stapleton objects to the definition of the term U.S. POSTAL SERVICE on the
grounds that it is overly broad, vague, and ambiguous, and would make compliance with the
term U.S. POSTAL SERVICE refers to the United States Postal Service. (U.S. POSTAL
SERVICE DEFINITION OBJECTION)

10
Amended General Objection 24: Stapleton objects to the definition of the term U.S.
POSTAL SERVICE on the grounds that it is overly broad, vague, ambiguous, and would make
compliance with the Requests unduly burdensome. For purposes of these Responses, Stapleton
understands that the term U.S. POSTAL SERVICE refers to the U.S. Postal Service, any d/b/a
thereof, and individuals or other entities known to Stapleton to have acted or purported to act on
behalf of such entities. (U.S. POSTAL SERVICE DEFINITION OBJECTION)
25. Stapleton objects to the definition of the term USPS TEAM on the grounds that
it is overly broad, vague, and ambiguous, and would make compliance with these requests
unduly burdensome. For purposes of these Responses, Stapleton understands that the term
USPS TEAM refers to the cycling team that was sponsored by the U.S. Postal Service
pursuant to the SPONSORSHIP AGREEMENTS during the 1995 to 2004 period. (USPS
TEAM DEFINITION OBJECTION)
Amended General Objection 25: Stapleton objects to the definition of the term USPS
TEAM on the grounds that it is overly broad, vague, ambiguous, and would make compliance
with the Requests unduly burdensome. For purposes of these Responses, Stapleton understands
that the term USPS TEAM refers to the USPS Team, any d/b/a thereof, and individuals or other
entities known to Stapleton to have acted or purported to act on behalf of such entities. (USPS
TEAM DEFINITION OBJECTION)
26. Stapleton objects to the definition of the term WADA on the grounds that it is
overly broad, vague, and ambiguous, and would make compliance with these requests unduly
burdensome. For purposes of these Responses, Stapleton understands that the term WADA
refers to the World Anti-Doping Agency. (WADA DEFINITION OBJECTION)
Amended General Objection 26: Stapleton objects to the definition of the term WADA
on the grounds that it is overly broad, vague, ambiguous, and would make compliance with the

11
term WADA refers to WADA, any d/b/a thereof and individuals or other entities known to
Stapleton to have acted or purported to act on behalf of such entities. (WADA DEFINITION
OBJECTION)
27. Stapleton objects to the definition of the terms YOU/YOUR on the grounds that
they are overly broad, vague, and ambiguous, and would make compliance with the requests
unduly burdensome. For purposes of these Responses, Stapleton understands that the terms
YOU/YOUR refer to defendant Capital Sports & Entertainment Holdings, Inc. (YOU
DEFINITION OBJECTION)
Amended General Objection 27: Stapleton objects to the definition of the term YOU on
term YOU refers to Stapleton, any d/b/a thereof, and individuals or other entities known to
Stapleton to have acted or purported to act on behalf of such entities. (YOU DEFINITION
OBJECTION)
28. Stapleton objects to Instruction No. 1 to the extent that it purports to impose
obligations on Stapleton that are not required under Rules 26 or 34 of the Federal Rules of Civil
Procedure or Local Civil Rule 26.2 of the rules of this Court. Particularly, Stapleton objects to
Instruction No. 1 to the extent that it calls for the production of documents that are not within
Stapletons possession, custody, or control.
Procedure or Local Civil Rule 26.2 of the rules of this Court. Stapleton further objects to
Instruction No. 2 to the extent that labeling documents to correspond to Relators categories

12
would be unreasonable or unduly burdensome or expensive, especially to the extent documents
are responsive to more than one category and/or to the extent that categorizing the documents
requires the application of legal analysis or conclusions, which may require the disclosure of
attorney work product.
30. Stapleton objects to Instruction No. 5 to the extent that it requires Stapleton to
prepare and provide a privilege log containing information that differs from, adds to, or is
otherwise inconsistent with the requirements of the Federal Rules of Civil Procedure or the rules
of this Court.
Procedure or Local Civil Rule 26.2 of the rules of this Court.
Procedure or Local Civil Rule 26.2 of the rules of this Court. Stapleton reiterates that
Stapletons Response to a particular Request to produce documents or provide information is not
an admission that any such documents or information exist.
33. Stapleton objects to Instruction No. 9 on the grounds that it is overly broad,
vague, and ambiguous, and would make compliance with these Requests unduly burdensome.
Amended Instruction No. 9: Unless otherwise stated, references in these requests to any
business entity include the business entity, any d/b/a thereof, and individuals or other entities
known to Stapleton to have acted or purported to act on behalf of such entities. Stapleton does
not object to Instruction No. 9, as amended.

13
34. Stapleton objects to Instruction No. 10 to the extent that it does not include a
reasonable time limitation and seeks documents that are neither relevant nor reasonably
calculated to lead to the discovery of admissible evidence.
35. Stapleton objects to Instruction No. 11 to the extent that it purports to impose an
obligation on Stapleton that is not required under the Federal Rules of Civil Procedure or the
rules of this Court.
SPECIFIC RESPONSES AND OBJECTIONS
In addition to the General Objections stated above, which are all hereby
incorporated into each and every response and objection set forth below, Stapleton responds and
objects to the specific Requests as follows:
REQUEST NO. 1:
ALL DOCUMENTS YOU have provided in response to the U.S. INVESTIGATION,
including, but not limited to, any DOCUMENTS YOU have provided in response to any
subpoena or other request for DOCUMENTS, in the same format as provided to the
United States, and with the same Bates numbering or any other numbering, if applicable.
RESPONSE TO REQUEST NO. 1:
Stapleton incorporates by reference his General Objections set forth above as if
fully set forth herein. Stapleton further specifically objects as follows:
YOU DEFINITION OBJECTION;
U.S. INVESTIGATION DEFINITION OBJECTION;
The Request is overbroad to the extent it includes documents provided in
response to any subpoena or other request for DOCUMENTS outside of
the U.S. INVESTIGATION; and
The term other request for DOCUMENTS is undefined, vague,
ambiguous, overly broad, and subject to varying interpretations.

14
Subject to and without waiving the foregoing objections, pursuant to Fed. R. Civ.
P. 26(a)(1)(A)(ii), Stapleton already produced a copy of the documents he produced to the
United States in response to a subpoena pertaining to this action with his initial disclosures in
this action.
AMENDED RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
Subject to and without waiving the foregoing objections, Stapleton will produce
the subpoena pursuant to which he produced the above-referenced documents and accompanying
certifications.
REQUEST NO. 2:
ALL DOCUMENTS YOU have provided to USADA RELATING TO the USADA
INVESTIGATION, in the same format as provided to USADA, and with the same Bates
numbering or any other numbering, if applicable.
USADA INVESTIGATION DEFINITION OBJECTION; and
USADA DEFINITION OBJECTION.
Subject to and without waiving the foregoing objections, Stapleton responds that
he has not produced documents to USADA in connection with any investigation or inquiry, as
Stapleton understands those terms, and therefore, has no documents that are responsive to the
Request. Stapleton is willing to meet and confer on the above-stated objections and issues.
non-privileged documents responsive to Request No. 2 that he discovers in his possession,

15
custody, or control after a diligent search to the extent such documents exist and have not
already been produced.
REQUEST NO. 3:
ALL DOCUMENTS YOU have provided to UCI RELATING TO any investigation or
inquiry by UCI, in the same format as provided to UCI, and with the same Bates
numbering or any other numbering, if applicable.
UCI DEFINITION OBJECTION;
The Request is vague, ambiguous, and overly broad, in particular because
it contains no time limitation; and
The term any investigation or inquiry by UCI is undefined, vague,
ambiguous, overly broad, and subject to varying interpretations.
Subject to and without waiving the foregoing objections, Stapleton believes
documents that were provided to UCI in connection with any investigation or inquiry, as
Stapleton understands those terms, are included in the documents identified in his Response to
Request No. 1, which have already been produced.

16
REQUEST NO. 4:
ALL DOCUMENTS YOU have provided in connection with any investigation or inquiry
into DOPING by any entity or person - other than the United States, USADA, or UCI - in
the same format as provided to such entity or person, and with the same Bates numbering
or any other numbering, if applicable.
USADA DEFINITION OBJECTION;
DOPING DEFINITION OBJECTION;
The term any investigation or inquiry into DOPING is undefined, vague,
ambiguous, overly broad, and subject to varying interpretations; and
The Request is overly broad and burdensome, particularly insofar as it
fails to identify the recipient of any such documents.
In light of the foregoing objections, Stapleton will not produce documents
responsive to this Request. Stapleton is willing to meet and confer on the above-stated
objections.
non-privileged DOCUMENTS YOU have provided in connection with any investigation or
inquiry by any person or entity into DOPING by Armstrong or the USPS Team other than any
investigation or inquiry by the United States, WADA, or UCI in the same format as provided
to such entity or person, and with the same Bates numbering or any other number, if applicable

17
that he discovers in his possession, custody, or control after a diligent search to the extent such
documents exist and have not already been produced.
REQUEST NO. 5:
ALL of your responses to discovery in any civil or administrative proceeding
RELATING TO allegations of DOPING by Armstrong or the USPS TEAM.
USPS TEAM DEFINITION OBJECTION;
The term any civil or administrative proceeding is undefined, vague,
fails to identify the parties to any such civil or administrative proceeding
and is not limited as to time or date.
objections.

18
REQUEST NO. 6:
ALL COMMUNICATIONS RELATING TO any inquiry or investigation RELATING
TO Lance Armstrong or the USPS TEAM by the United States, USADA, USA Cycling
or UCI.
The terms any inquiry or investigation and USA Cycling are
undefined, vague, ambiguous, overly broad, and subject to varying
interpretations;
fails to identify the parties to such communications and fails to specify the
topic of any inquiry or investigation;
The Request is overly broad and burdensome in that it seeks documents
that are neither relevant nor reasonably calculated to lead to the discovery
of admissible evidence, as it seeks communications relating to any
inquiry or investigation regardless of whether such inquiry or
investigation concerned doping; and
The Request potentially seeks the production of documents protected by
the attorney-client privilege and/or work product doctrine.
objections.

19
non-privileged COMMUNICATIONS RELATING TO any inquiry or investigation
RELATING TO DOPING by Lance Armstrong or the USPS TEAM by the United States,
USADA, USA Cycling, or UCI that he discovers in his possession, custody, or control after a
diligent search to the extent such documents exist and have not already been produced.
REQUEST NO. 7:
ALL COMMUNICATIONS between YOU and any other person or entity RELATING
TO any investigation of DOPING in cycling, including, but not limited to, the following:
the U.S. INVESTIGATION; the USADA INVESTIGATION; any investigation or
inquiry associated with the UCI or any related commission or organization; the French
investigation into the use of Actovegin by the USPS Team in 2000; the Italian criminal
investigation into Michelle Ferrari; the investigation into LEquipes allegations in 2005
that Lance Armstrong used EPO during the 1999 Tour De France; the Festina affair in
1998; and Operation Puerto in 2006.
USADA INVESTIGATION DEFINITION OBJECTION;
The terms investigation, inquiry, and any related commission or
organization are undefined, vague, ambiguous, overly broad, and subject
to varying interpretations;

20
of admissible evidence; and
objections.
non-privileged COMMUNICATIONS between YOU and any other person or entity
RELATING TO any investigation of DOPING in cycling, including, but not limited to, the
following: the U.S. INVESTIGATION; the USADA INVESTIGATION; any investigation or
inquiry associated with the UCI or any related commission or organization; the French
investigation into the use of Actovegin by the USPS Team in 2000; the Italian criminal
investigation into Michelle Ferrari; the investigation into LEquipes allegations in 2005 that
Lance Armstrong used EPO during the 1999 Tour De France; the Festina affair in 1998 that he
discovers in his possession, custody, or control after a diligent search to the extent such
The phrase any related commission or organization includes the following: the
organization responsible for the Vrijham Report in 2006, the UCI Independent Commission
created in 2012, the Cycling Independent Reform Commission (CIRC) created in 2013, and
the organization responsible for A Report on Corruption in the Leadership of the Union Cycliste
Internationale (The Report), which has also been referred to in the media as The Dossier.

21
REQUEST NO. 8:
ALL COMMUNICATIONS between YOU and any person or entity RELATING TO any
allegations in books, news articles or other media outlets regarding DOPING by Lance
Armstrong or the USPS Team.
The terms allegations and other media outlets are undefined, vague,
ambiguous, overly broad, and subject to varying interpretations;
objections.
non-privileged COMMUNICATIONS between YOU and any person or entity RELATING TO
any allegations in books, news articles or web-based publications or television programs
regarding DOPING by Lance Armstrong or the USPS Team that he discovers in his possession,

22
REQUEST NO. 9:
ALL DOCUMENTS RELATING TO the U.S. INVESTIGATION, the USADA
INVESTIGATION, DOPING, or this case.
The term this case is undefined, vague, ambiguous, overly broad, and
subject to varying interpretations;
of admissible evidence, particularly in that it seeks the production of all
documents relating to DOPING regardless of whether they concern the
USPS TEAM or even bicycle racing; and
objections.


23
non-privileged documents referring to or mentioning the U.S. INVESTIGATION, the USADA
INVESTIGATION, DOPING by any member of the USPS TEAM, or this case that he
The phrase this case refers to the instant civil action U.S. ex rel Landis v.
Tailwind, et al., Case No. 1:10-cv-00976-RLW (D.D.C.). The term DOPING refers to the use
of prohibited substances or prohibited methods to increase performance in professional bicycle
racing and includes the use of EPO, testosterone, corticosteroid, blood transfusions and/or
masking agents.
REQUEST NO. 10:
ALL COMMUNICATIONS or DOCUMENTS RELATING TO any alleged failure by
Lance Armstrong or any other rider on the USPS TEAM to comply with testing for
DOPING or evading testing for DOPING.
The terms failure to comply and evading testing are undefined, vague,
The Request is vague, ambiguous, and overly broad, in particular due to
the use of RELATING TO in this context;

24
objections. Subject to and without waiving the foregoing objections, Stapleton believes
documents responsive to this Request, to the extent Stapleton is able to understand it, are
included in the documents identified in his Response to Request No. 1, which have already been
produced.
REQUEST NO. 11:
ALL DOCUMENTS and COMMUNICATIONS RELATING TO denials of DOPING by
TAILWIND, the USPS TEAM or any of the riders on the team.
TAILWIND DEFINITION OBJECTION;
The term denials is undefined, vague, ambiguous, overly broad, and

25
it contains no time limitation;
the use of RELATING TO in this context; and
objections.
Subject to and without waiving the foregoing objections, and despite Relators
unwarranted allegations in its correspondence concerning Request No. 11 and without admitting
them, Stapleton will produce non-privileged documents responsive to Request No. 11 that he
REQUEST NO. 12:
ALL DOCUMENTS RELATING TO any positive, potentially positive, or abnormal test
results for DOPING by Lance Armstrong or any other rider on the USPS TEAM.
USPS TEAM OBJECTION;
The Request seeks the production of documents not within Stapletons
possession, custody or control; and

26
The terms positive, potentially positive, and abnormal test results
are undefined, vague, ambiguous, overly broad, and subject to varying
interpretations.
relevant, nonprivileged documents he discovers after a diligent search that are responsive to this
Request. Stapleton believes documents responsive to this Request are included in the documents
identified in his Response to Request No. 1, which have already been produced.
REQUEST NO. 13:
ALL COMMUNICATIONS preserved on an audio or video recording, in which any part
of the COMMUNICATION relates to DOPING.
of admissible evidence, particularly in that it seeks the production of all
communications relating to DOPING regardless of whether they
concern the USPS TEAM or even bicycle racing; and
Request.

27
non-privileged COMMUNICATIONS preserved on an audio or video recording RELATING to
DOPING by Armstrong of the USPS Team or DOPING in cycling in his possession, custody,
or control after a diligent search to the extent such documents exist and have not already been
produced.
REQUEST NO. 14:
ALL WRITTEN CONTRACTS of any type between YOU, or any entity controlled by
YOU, and any of the other DEFENDANTS.
YOU DEFINITION OBJECTION; and
of admissible evidence.
Request.
REQUEST NO. 15:
ALL WRITTEN CONTRACTS between Lance Armstrong and any entity other than
TAILWIND which operated a cycling team.

28
possession, custody, or control; and
Request.
REQUEST NO. 16:
ALL WRITTEN CONTRACTS, which referred to or RELATED TO the USPS Team,
Lance Armstrong or cycling, between any person or entity who was a sponsor of the
USPS TEAM and any of the following: TAILWIND, ANY OF THE CSE RELATED
ENTITIES, Tailwind Capital Partners, THOMAS WEISEL PARTNERS, Thomas
Weisel, ROSS INVESTMENTS, Livestrong, Johan Bruyneel, YOU or Bart Knaggs.
ANY OF THE CSE RELATED ENTITIES DEFINITION OBJECTION;
THOMAS WEISEL PARTNERS DEFINITION OBJECTION;
ROSS INVESTMENTS DEFINITION OBJECTION;
The terms Tailwind Capital Partners, Livestrong, and sponsor of the
USPS TEAM are undefined, vague, ambiguous, overly broad, and

29
Request.
REQUEST NO. 17:
ALL COMMUNICATIONS and DOCUMENTS RELATING TO Lance Armstrongs
rider contracts with TAILWIND.
The term rider contracts is undefined, vague, ambiguous, overly broad,
and subject to varying interpretations; and

30
REQUEST NO. 18:
ALL DOCUMENTS RELATING TO the SPONSORSHIP AGREEMENTS, including,
but not limited to, all executed copies, drafts, amendments, novations, modifications,
extensions, exhibits thereto, and any correspondence or other COMMUNICATIONS
relating thereto.
The terms drafts, novations, and modifications are undefined,
vague, ambiguous, overly broad, and subject to varying interpretations;
Request.
REQUEST NO. 19:
ALL of TAILWINDs WRITTEN CONTRACTS with any entities other than the U.S.
POSTAL SERVICE RELATING TO sponsorship of the USPS TEAM, including, but not
limited to, executed copies of such agreements.

31
U.S. POSTAL SERVICE DEFINITION OBJECTION;
Request.
REQUEST NO. 20:
ALL WRITTEN CONTRACTS of TAILWIND, or any rider on the USPS TEAM, or any
sponsor of the USPS TEAM which contain a morals clause or a reference to DOPING,
including, but not limited do, any sponsorship or promotion agreements.
The terms any sponsor of the USPS TEAM, morals clause, and
sponsorship or promotion agreements are undefined, vague, ambiguous,
overly broad, and subject to varying interpretations;
of admissible evidence, in particular as it requests contracts between

32
sponsors of the USPS TEAM and other entities uninvolved with the
claims in this lawsuit;
produced.
REQUEST NO. 21:
ALL WRITTEN CONTRACTS between TAILWIND and its riders.
The term its riders is undefined, vague, ambiguous, overly broad, and

33
REQUEST NO. 22:
ALL DOCUMENTS RELATING to any cancellations of, or any other changes to, any
sponsor agreement RELATING TO DOPING by Lance Armstrong or DOPING by any
other rider for TAILWIND.
The terms cancellations of, other changes to, and sponsor
agreement are is undefined, vague, ambiguous, overly broad, and subject
to varying interpretations;
of admissible evidence;

34
The Request is vague, ambiguous, and nonsensical.
objections.
non-privileged DOCUMENTS RELATING to any cancellations of, or any other changes to, any
sponsor agreement based upon DOPING by Lance Armstrong or DOPING by any other rider for
TAILWIND for the time period prior to the filing of this lawsuit that he discovers in his
possession, custody, or control after a diligent search to the extent such documents exist and
have not already been produced.
To further clarify, this Request is meant to refer to instances where a sponsor
agreement was cancelled or changed based on the sponsor becoming aware of DOPING or
allegations of DOPING by Armstrong or another rider for Tailwind during the time period prior
to the filing of this lawsuit.
REQUEST NO. 23:
ALL DOCUMENTS or COMMUNICATIONS RELATING TO claims for payment to
the U.S. POSTAL SERVICE under the SPONSORSHIP AGREEMENTS, including but
not limited to claims for payment for services provided by CSE, Knaggs, or YOU.
CSE DEFINITION OBJECTION;

35
The term claims for payment is undefined, vague, ambiguous, overly
broad, and subject to varying interpretations;
Request. Stapletons production will be limited to documents reflecting requests for payments,
rather than RELATING TO the requests for payments. Stapleton is willing to meet and confer
on the above-stated objections and issues. Stapleton believes documents responsive to this
Request are included in the documents identified in his Response to Request No. 1, which have
non-privileged (1) DOCUMENTS reflecting requests for payments and (2) DOCUMENTS that
indicate DEFENDANTS knew the claims were false, that DEFENDANTS acted with reckless
disregard with regard to the truth of the claims, that DEFENDANTS were aware that DOPING
by the USPS Team would make the claims false, and any statements regarding the fact that the
claims were false, he discovers in his possession, custody, or control after a diligent search to
the extent such documents exist and have not already been produced.
REQUEST NO. 24:
ALL DOCUMENTS RELATING TO TAILWINDs receipt of payments from the U.S.
POSTAL SERVICE under the SPONSORSHIP AGREEMENTS.

36
The term receipt of payments is undefined, vague, ambiguous, overly
Request. Stapletons production will be limited to documents reflecting the receipt of such
payments, rather than RELATING TO the receipt of such payments. Stapleton is willing to
meet and confer on the above-stated objections and issues.
non-privileged (1) DOCUMENTS reflecting the receipt of such payments and (2)
DOCUMENTS that show the DEFENDANTS knew they were not or may not be entitled to
payments, he discovers in his possession, custody, or control after a diligent search to the
extent such documents exist and have not already been produced.
REQUEST NO. 25:
ALL articles of incorporation, amended articles of incorporation, articles of organization,
amended articles of organization, operating agreements, bylaws, amended bylaws, and
shareholder registers of TAILWIND from 1987 through December 31, 2007.

37
The Request is unreasonable in time and scope, in particular in that it
seeks documents from over 25 years ago and for a period of approximately
20 years;
Request.
REQUEST NO. 26:
ALL filings with any state government entity or the Securities and Exchange
Commission by TAILWIND from 1987 through the present.

38
27 years.
Request.
REQUEST NO. 27:
The DOCUMENTS used to accomplish the sale of TAILWINDs shares to its
shareholders or partners.
The term used to accomplish is undefined, vague, ambiguous, overly
broad, and subject to varying interpretations and nonsensical as used in the
Request;
The Request is vague, ambiguous, and nonsensical.

39
objections.
For the purpose of this Request, the phrase used to accomplish refers to those
DOCUMENTS necessary for the subject transactions to have taken place, including, but not
limited to, the buyout of Montgomery Sports, Inc. stock from Montgomery Securities, the sale of
stock of Montgomery Sports, Inc. (aka TWP Sports, Inc.) to Tailwind Sports LLC, the merger of
Tailwind Sports LLC into Tailwind Sports Corporation, and the sale of stock of Tailwind Sports
Corporation through private placements or otherwise.
REQUEST NO. 28:
ALL DOCUMENTS RELATING TO the sale of TAILWIND shares to YOU.
TAILWIND DEFINITION OBJECTION; and

40
REQUEST NO. 29:
ALL DOCUMENTS RELATING TO the sale of TAILWIND shares to Thomas Weisel,
Johan Bruyneel, Lance Armstrong, Bart Knaggs, or CSE.
possession, custody, or control;
REQUEST NO. 30:
DOCUMENTS sufficient to show the ownership interests in TAILWIND from 1987
through the date of its dissolution.

41
The terms sufficient to show, ownership interests, and date of its
dissolution are undefined, vague, ambiguous, overly broad, and subject to
varying interpretations;
20 years; and
possession, custody, or control.
objections.
REQUEST NO. 31:
DOCUMENTS that show the officers, directors, employees and agents of TAILWIND
from 1987 through the present.

42
The terms employees and agents are undefined, vague, ambiguous,
27 years; and
objections.
REQUEST NO. 32:
ALL DOCUMENTS that show the ownership interests in THOMAS WEISEL
PARTNERS held by any shareholder, officer, director, employee or agent of
TAILWIND, from January 1, 1999 through the present.

43
The terms employee and agent are undefined, vague, ambiguous,
15 years; and
objections.
REQUEST NO. 33:
ALL DOCUMENTS that show the ownership interests in Montgomery Securities held by
any shareholder, officer, director or employee of TAILWIND, from 1987 through the
date Montgomery Securities ceased to exist.
The terms employee and Montgomery Securities are undefined,

44
15 years, as Relator alleges in his complaint that Montgomery Securities
ceased to exist at the latest in 1999 (Dkt. No. 42, 7); and
objections.
REQUEST NO. 34:
ALL board minutes of TAILWIND from January 1, 1987 through December 31, 2007.
20 years; and
the attorney-client privilege and/or work product doctrine; and

45
objections.
REQUEST NO. 35:
ALL DOCUMENTS showing what the assets of Tailwind Sports Corporation were upon
its dissolution and how such assets were distributed.
The terms assets, Tailwind Sports Corporation, and distributed are
interpretations;
REQUEST NO. 36:
ALL annual or other periodic financial statements (including balance sheets and profit
and loss statements) for TAILWIND from 1995 through the present.

46
The terms other periodic, financial statements, balance sheets, and
profit and loss statements are undefined, vague, ambiguous, overly
seeks documents from approximately 19 years ago and for a period of
approximately 19 years; and
REQUEST NO. 37:
ALL Private Placement Memoranda issued by TAILWIND from 1995 through the
present.

47
The terms Private Placement Memoranda and issued by are
interpretations;
Request.
REQUEST NO. 38:
TAILWINDs federal and state income tax returns from 1995 through the present.

48
Request subject to and after the entry of a suitable protective order.
REQUEST NO. 39:
The General Ledger(s) or any other accounting records showing the funds flowing into
and out of TAILWIND from 1995 through 2007.
The terms General Ledger(s) and other accounting records, are
interpretations;
The phrase showing the funds flowing into and out of is undefined,

49
produced
REQUEST NO. 40:
ALL DOCUMENTS and COMMUNICATIONS RELATING to the capitalization or
undercapitalization of TAILWIND.
The terms capitalization and undercapitalization are undefined, vague,
The Request is unreasonable in time and scope, in particular because it
contains no limitation as to time;

50
REQUEST NO. 41:
ALL DOCUMENTS RELATING TO the dissolution of TAILWIND and the distribution
of its assets to shareholders.
The phrase distribution of its assets is undefined, vague, ambiguous,
the attorney-client privilege and/or work product doctrine; and

51
REQUEST NO. 42:
ALL DOCUMENTS used to accomplish the sale of stock of Montgomery Sports, Inc. by
Montgomery Securities to Thomas Weisel or any entity affiliated with him.
The terms Montgomery Sports, Inc., Montgomery Securities, and
any entity affiliated with him are undefined, vague, ambiguous, overly
The phrase used to accomplish is undefined, vague, ambiguous, overly
broad, and subject to varying interpretations and nonsensical as used in
this Request; and
Request.
REQUEST NO. 43:
ALL DOCUMENTS used to accomplish the sale of stock of Montgomery Sports, Inc. to
Tailwind Sports, LLC.

52
The terms Montgomery Sports, Inc. and Tailwind Sports, LLC are
interpretations;
this Request; and
Request.
REQUEST NO. 44:
ALL DOCUMENTS used to accomplish the merger of Tailwind Sports, LLC into
Tailwind Sports Corporation.
The terms Tailwind Sports, LLC and Tailwind Sports Corporation are
interpretations;

53
this Request; and
Request.
REQUEST NO. 45:
ALL DOCUMENTS RELATING TO payments by others (including, but not limited to,
Thomas Weisel) for the debts or expenses or any other obligation of TAILWIND.
The terms others and any other obligation are undefined, vague,

54
produced.
REQUEST NO. 46:
ALL DOCUMENTS RELATING TO diversion of TAILWINDs funds or assets to non-
corporate uses, including but not limited to the following: payments for non-business
related expenses to shareholders, officers, directors, employees or their families or any
business entities in which they held an interest.
The terms diversion, non-corporate uses, non-business related
expenses, and business entities in which they held an interest are
interpretations; and

55
Request.
REQUEST NO. 47:
ALL DOCUMENTS showing any payments or transfers of funds from Thomas Weisel,
or THOMAS WEISEL PARTNERS, or any account controlled in whole or in part by
Thomas Weisel, to YOU, Johan Bruyneel, to Lance Armstrong, or to any other rider on
the USPS TEAM.
The term any account controlled in whole or in part is undefined, vague,
The Request is vague, ambiguous, and nonsensical to the extent it suggests
Stapleton was a rider on the USPS TEAM; and

56
REQUEST NO. 48:
ALL DOCUMENTS RELATING TO any loans by Thomas Weisel or THOMAS
WEISEL PARTNERS to TAILWIND, YOU, Johan Bruyneel, Lance Armstrong, or any
rider on the USPS TEAM.
The Request is vague, ambiguous, and nonsensical to the extent it suggests
Stapleton was a rider on the USPS TEAM; and
REQUEST NO. 49:
ALL DOCUMENTS showing any payments or transfers of funds from Thomas Weisel or
THOMAS WEISEL PARTNERS, or any account controlled in whole or in part by
Thomas Weisel, to TAILWIND.

57
of admissible evidence, in particular because it requests documents
showing any payment or transfer of funds regardless of purpose;
contains no limitation as to time; and
REQUEST NO. 50:
ANY DOCUMENTS showing the location of TAILWINDs office space between 1995
and 2007, including but not limited to any space occupied by TAILWIND in the offices
of Montgomery Securities or Thomas Weisel Partners.

58
The terms Montgomery Securities, office space, and Thomas Weisel
Partners are undefined, vague, ambiguous, overly broad, and subject to
varying interpretations;
requests documents from approximately 17 years ago and from a period of
12 years; and
objections.
REQUEST NO. 51:
ALL DOCUMENTS RELATING TO the value of and/or the price paid for any office
space occupied by TAILWIND at Montgomery Securities or Thomas Weisel Partners,
including, but not limited to, any lease documents or other DOCUMENTS which show
the rental rates for such space from one year prior to the date that TAILWIND occupied
the space to one year after TAILWIND vacated the space.

59
The terms Montgomery Securities, Thomas Weisel Partners, and
value of are undefined, vague, ambiguous, overly broad, and subject to
varying interpretations; and
objections.
REQUEST NO. 52:
ALL DOCUMENTS or COMMUNICATIONS RELATING TO any funds deposited
with THOMAS WEISEL PARTNERS or Robert W. Baird by Hein Verbruggen, by any
entity owned or controlled by Hein Verbruggen, or by any relative of Hein Verbruggen.
concerning deposits regardless of purpose;
The terms any entity owned or controlled by Hein Verbruggen and any
relative of Hein Vebruggen are undefined, vague, ambiguous, overly
The Request potentially seeks information that would constitute an
invasion of privacy;

60
objections.
REQUEST NO. 53:
ALL DOCUMENTS or COMMUNICATIONS RELATING TO any funds managed by
or deposited with THOMAS WEISEL PARTNERS for the benefit of any individual
currently or formerly affiliated with UCI or USA CYCLING (or for any entity which
such individual owns or controls).
USA CYCLING DEFINITION OBJECTION;

61
concerning deposits regardless of purpose and fails to identify the relevant
individual[s] currently or formerly affiliated with UCI or USA
CYCLING or any entity such individuals own[] or control[];
The terms managed by, deposited with, for the benefit of, affiliated
with, and controls are undefined, vague, ambiguous, overly broad, and
The Request potentially seeks information that would constitute an
invasion of privacy;
contains no limitation as to time or scope;
The request seeks the production of documents protected by the attorney-
client privilege and/or work product doctrine; and
objections.
REQUEST NO. 54:
ALL DOCUMENTS or COMMUNICATIONS RELATING TO payments by Thomas
Weisel or THOMAS WEISEL PARTNERS to the UCI OR any person affiliated with the
UCI.

62
concerning payments regardless of purpose;
The term affiliated with is undefined, vague, ambiguous, overly broad,
and subject to varying interpretations;
contains no limitation as to time or scope;
objections.

63
REQUEST NO. 55:
ALL DOCUMENTS RELATING TO Thomas Weisels change in position from
President to Chairman of TAILWIND.
The term change in position is undefined, vague, ambiguous, overly
broad, and subject to varying interpretations; and
REQUEST NO. 56:
ALL DOCUMENTS RELATING TO the transaction or decision by which CSE, YOU or
Bart Knaggs took on management responsibilities at TAILWIND.

64
The terms transaction or decision, took on, and management
responsibilities are undefined, vague, ambiguous, overly broad, and
subject to varying interpretations; and
REQUEST NO. 57:
ALL COMMUNICATIONS RELATING TO the transaction or decision by which CSE,
YOU or Bart Knaggs took on management responsibilities at TAILWIND.

65
The terms transaction or decision, took on, and management
responsibilities are undefined, vague, ambiguous, overly broad, and
REQUEST NO. 58:
ALL DOCUMENTS RELATING TO any DEFENDANTs involvement in the
submission of claims for payment to, or the receipt of payments from, the U.S. POSTAL
SERVICE.
The terms involvement in and claims are undefined, vague,

66
REQUEST NO. 59:
ALL DOCUMENTS showing whether claims for payments were copied to any
DEFENDANT or showing they were otherwise made aware of any claim for payment
submitted by TAILWIND to the U.S. POSTAL SERVICE.
The terms were copied to any DEFENDANT, were otherwise made
aware, and claim are undefined, vague, ambiguous, overly broad, and
REQUEST NO. 60:
ALL DOCUMENTS showing whether any DEFENDANT received copies of the
SPONSORSHIP AGREEMENTS or was made aware of the terms thereof.

67
The term was made aware is undefined, vague, ambiguous, overly
Request.
REQUEST NO. 61:
ALL DOCUMENTS showing whether any DEFENDANT was aware of any positive or
inconclusive DOPING testing results by any rider on the USPS TEAM

68
The terms positive and inconclusive are undefined, vague, ambiguous,
overly broad, and subject to varying interpretations; and
Request.
REQUEST NO. 62:
ALL DOCUMENTS showing whether any DEFENDANT was copied on or was
otherwise made aware of the terms of Lance Armstrongs rider contract, or the rider
contract of any rider on the USPS TEAM.
The terms was copied on, was otherwise made aware, and rider
contract are undefined, vague, ambiguous, overly broad, and subject to
Request.

69
REQUEST NO. 63:
ALL DOCUMENTS RELATING TO ANY DEFENDANTS contention that the United
States or the U.S. POSTAL SERVICE knew or should have known of DOPING on the
USPS TEAM.
The terms ANY DEFENDANTS contention and should have known
interpretations;
The Request is vague, ambiguous, and overly broad; and
objections.
all communications with the U.S. Postal Service that he discovers in his possession, custody, or
control after a diligent search to the extent such documents exist and have not already been
produced. Stapleton reserves his right to supplement this response as discovery and investigation
continue.

70
REQUEST NO. 64:
ALL DOCUMENTS RELATING TO THE response of the UNITED STATES to
allegations of DOPING by Lance Armstrong or any other rider on the USPS TEAM.
The terms UNITED STATES, and response of the UNITED STATES
interpretations;
objections.
already been produced. Stapleton reserves his right to supplement this response as discovery and
investigation continue.

71
REQUEST NO. 65:
ALL DOCUMENTS RELATING TO the value of what the U.S. POSTAL SERVICE
received under the SPONSORSHIP AGREEMENTS, including but not limited to any
valuations, audits, or marketing analyses.
The terms value, what the U.S. POSTAL SERVICE received,
valuations, audits, and marketing analyses are undefined, vague,
Request. Stapletons production will be limited to documents reflecting the value, rather than
RELATING TO the value. Stapleton is willing to meet and confer on the above-stated
objections and issues. Stapleton believes documents responsive to this Request are included in
the documents identified in his Response to Request No. 1, which have already been produced.
REQUEST NO. 66:
ALL DOCUMENTS RELATING TO the damages suffered by the U.S. POSTAL
SERVICE as a result of DOPING by the USPS TEAM, Lance Armstrong, or any other
member of the USPS TEAM.

72
The Request assumes facts for which there is no basis, namely that the
U.S. POSTAL SERVICE has suffered any damages; and
objections.
Subject to and without waiving the foregoing objections, Stapleton represents that
he has no documents responsive to this Request, as the U.S. Postal Service has suffered no
damages in connection with the subject matter of this case.
REQUEST NO. 67:
ALL DOCUMENTS RELATING TO any contention that the U.S. POSTAL SERVICE
was not damaged as a result of DOPING by the USPS TEAM, Lance Armstrong, or any
other member of the USPS TEAM.

73
objections.
already been produced. Stapleton reserves his right to supplement this response as discovery and
investigation continue.
REQUEST NO. 68:
ALL DOCUMENTS OR COMMUNICATIONS RELATING TO Floyd Landis.
of admissible evidence, in particular as it seeks documents or
communications relating to Floyd Landis without any limitation on the
subject matter of such documents or communications or any limitation on
the applicable time period.

74
objections.
non-privileged documents that refer to or mention Floyd Landis that he discovers in his
possession, custody, or control after a diligent search to the extent such documents exist and
In response to Relators counsels June 30, 2014 letter, Stapleton does not intend
to exclude communications from his production in response to this Request. Further, Stapleton
will also include any documents referencing Mr. Landis by his first name, last name, any
nicknames known to Stapleton, and his email address to the extent such documents exist and
REQUEST NO. 69:
ALL DOCUMENTS that contradict the allegations of the United States or the relator in
this case.
objections.

75
As discussed extensively during meet and confer communications with Relators
counsel, Stapleton cannot search for documents responsive to this Request, and therefore, cannot
produce documents responsive to it.
REQUEST NO. 70:
ALL DOCUMENTS upon which YOU rely to deny the allegations of the United States
or the relator in their respective complaints against YOU in this case.
The Request is vague, ambiguous, and overly broad;
The Request is premature as discovery in this action has just commenced
and document may be produced by other parties or discovered
subsequently by Stapleton upon which Stapleton may rely to deny the
allegations made by Relator in this action;
United States has filed a complaint against Stapleton; and
objections.

76
As discussed extensively during meet and confer communications with Relators
counsel, Stapleton cannot search for documents responsive to this Request, and therefore, cannot
produce documents responsive to it.
REQUEST NO. 71:
ALL DOCUMENTS OR COMMUNICATIONS RELATING TO this case.
objections.
non-privileged DOCUMENTS or COMMUNICATIONS referring to or mentioning this action
he discovers in his possession, custody, or control after a diligent search to the extent such
This action refers to U.S. ex rel. Landis v. Tailwind, et al., Case No. 1:10-cv-
00976-RLW (D.D.C.).

77
REQUEST NO. 72:
ALL COMMUNICATIONS RELATING TO DOPING, the U.S. INVESTIGATION, the
USADA INVESTIGATION, or this case with any persons affiliated with the news media
as well as any DOCUMENTS related thereto.
objections.
REQUEST NO. 73:
ALL DOCUMENTS that YOU may use to support any affirmative defenses YOU have
against the allegations of the United States or the relator in this case.

78
The Request is vague, ambiguous, and overly broad;
The Request is premature as discovery in this action has just begun,
Stapleton has not yet answered Relators Second Amended Complaint,
and Stapleton does not yet know which documents it may rely upon in
support of any affirmative defense in this action;
United States has filed a complaint against Stapleton; and
objections.
The Request is premature as Stapleton has not yet filed an answer or asserted
affirmative defenses in this case. Stapleton will produce documents responsive to this Request
after he asserts affirmative defenses in this case. Stapleton reserves his right to supplement this
response as discovery and investigation continue.
REQUEST NO. 74:
ALL privilege logs RELATING TO the U.S. INVESTIGATION, the USADA
INVESTIGATION, or any claims or litigation against YOU RELATING TO DOPING.

79
The term any claims or litigation against YOU RELATING TO
DOPING is undefined, vague, ambiguous, overly broad, and subject to
The Request is vague, ambiguous, and overly broad.
objections.
Subject to and without waiving the foregoing objections, Stapleton represents that
he has no documents responsive to this Request.
REQUEST NO. 75:
ALL COMMUNICATIONS and DOCUMENTS relating to any investigation YOU have
conducted relating to the U.S. INVESTIGATION, the USADA INVESTIGATION, or
this case, including, but not limited to, any video-taping, audio recording, or any other
forms of surveillance or background investigation.

80
The terms other forms of surveillance and background investigation
interpretations;
The Request is vague, ambiguous, and overly broad
objections.
REQUEST NO. 76:
ALL DOCUMENTS or COMMUNICATIONS RELATING TO ANY statements,
transcripts, declarations, interviews or summaries of interviews of any persons
RELATING TO the U.S. INVESTIGATION, the USADA INVESTIGATION, or this
case.

81
The terms statements and summaries of interviews are undefined,
objections.
For purposes of this Request, the term statements refers to written statements by
any of the DEFENDANTS, Relator, U.S. Postal Service, or any potential witnesses. The phrase
summaries of interviews refers to written summaries of interviews of any of the
DEFENDANTS, Relator, U.S. Postal Service, or any potential witness.

82
REQUEST NO. 77:
ALL contracts between YOU, on the one hand, and any of the CSE RELATED
ENTITIES, on the other hand.
CSE RELATED ENTITIES DEFINITION OBJECTION;
The term contracts is undefined, vague, ambiguous, overly broad, and
The request potentially seeks the production of documents protected by
the attorney-client privilege and/or work product doctrine;
REQUEST NO. 78:
ALL DOCUMENTS that describe the nature of the services YOU or any of the CSE
RELATED ENTITIES have provided for Lance Armstrong from 1995 through the
present.

83
The term nature of the services is undefined, vague, ambiguous, overly
The Request is unreasonable in scope and time, as it seeks documents
from a period of approximately 19 years.
objections.
(1) all contracts or engagement letters entered into between the CSE Defendants and Mr.
Armstrong, (2) all documents that reflect or refer to Mr. Stapletons status with the Texas bar,
and (3) any communications between Mr. Stapleton and Mr. Armstrong in which either party
expressly stated that Mr. Stapleton either was or was not acting as Mr. Armstrongs attorney, that
REQUEST NO. 79:
ALL DOCUMENTS establishing or evidencing an attorney-client relationship between
YOU OR the CSE RELATED ENTITIES, on the one hand, AND Lance Armstrong, on
the other, at any point between 1995 and the present.

84
from a period of approximately 19 years; and
objections.
REQUEST NO. 80:
ALL DOCUMENTS evidencing the lack of an attorney-client relationship between YOU
OR the CSE RELATED ENTITIES, on the one hand, and Lance Armstrong, on the other,
at any point between 1995 and the present.

85
The Request assumes facts for which there is no basis, namely that an
attorney-client relationship did not exist;
objections.

86
REQUEST NO. 81:
ALL DOCUMENTS RELATING TO YOUR authorization or lack of authorization to
practice law at any point between 1995 and the present.
The terms authorization, lack of authorization, and at any point are
interpretations;
objections.

87
REQUEST NO. 82:
ALL DOCUMENTS RELATING TO Lance Armstrongs knowledge or lack thereof that
YOU were inactive or unauthorized to practice law at any point between 1995 and the
present.
Request.
REQUEST NO. 83:
ALL COMMUNICATIONS RELATING TO whether or not YOU were acting as Lance
Armstrongs attorney.

88
The term acting as Lance Armstrongs attorney is undefined, vague,
The Request is unreasonable in scope and time, as it is unlimited in time
and scope; and
objections.
REQUEST NO. 84:
ALL contracts between any of the CSE RELATED ENTITIES, on the one hand, and
Lance Armstrong , on the other, including, but not limited to, any engagement letters,
retainer agreements, or other agreements describing any services to be provided to Lance
Armstrong.

89
The term other agreements describing any services to be provided is
interpretations;
Request.

90
REQUEST NO. 85:
ALL articles of incorporation, amended articles of incorporation, bylaws, amended
bylaws, and shareholder registers of the CSE RELATED ENTITIES.
RESPONSE TO REQUEST NO. 85
Request.
REQUEST NO. 86:
All filings with the California Secretary of State, the Delaware Secretary of State, or the
Securities and Exchange Commission by the CSE RELATED ENTITIES from 1995
through the present.

91
Request.
REQUEST NO. 87:
DOCUMENTS that list the breakdown in ownership of the CSE RELATED ENTITIES
at any or all points from 1995 through the present.
The terms breakdown in ownership and any or all points are
interpretations; and

92
REQUEST NO. 88:
DOCUMENTS that list the officers, directors, employees and agents of the CSE
RELATED ENTITIES at any or all points from 1995 through the present.
The terms employees, agents, and any or all points are undefined,
and

93
produced.
DOCUMENTS sufficient to show the officers and directors and full-time employees of CSEs
sports group between 1995 and the present.
REQUEST NO. 89:
ALL board minutes from 1995 through the present of CSE.
objections.

94
board minutes of CSE that have touched on the matter of doping or other allegations in this case.
REQUEST NO. 90:
ALL COMMUNICATIONS between YOU and ANY of the following people or entities:
a. Lance Armstrong
b. Johan Bruyneel
c. Thomas Weisel
d. Barton Knaggs
e. the United States Postal Service or any current or former employee or
agent of the United States Postal Service
f. Thomas Weisel Partners
g. Mark Gorski
h. Dan Osipow
i. Jim Ochowicz
j. Emma OReilly
k. Geert Duffeleer
l. Laurenzo Lapage
m. Edward Eddie B Borysewicz
n. Johnny Weltz
o. Stephanie McIlvain
p. Laura Hundley
q. Dr. Pedro Celaya
r. Dr. Luis Garcia del Moral
s. Dr. Michele Ferrari
t. Dr. Jose Aramendi
u. Dr. Dag Van Elsland
v. Dr. Eufemeniano Fuentes
w. Dr. Herman Falsetti
x. Jose Pepe Marti
y. Philippe Maire
z. Hein Verbruggen
aa. Pat McQuaid
bb. Emile Vrijman
cc. Philippe Verbiest
dd. Sylvia Shenk
ee. Dr. Mario Zorzoli
ff. Steve Johnson
gg. Floyd Landis

95
contains no limitation as to time;
produced.
The parties have agreed to continue to meet and confer with respect to Request
No. 90. Accordingly, the parties have agreed to a staged production of electronic documents
based on custodians specified by Relators counsel. Relators counsel will use the list of
personnel provided in response to Request No. 88 to identify custodians of interest. Once the
custodians of interest have been provided, the parties will then confer regarding which persons
from the list above are appropriate search terms for that particular custodian of interest.

96
REQUEST NO. 91:
ALL DOCUMENTS RELATING TO payments to Johan Bruyneel or to Johan Bruyneel
Sports Management by TAILWIND or by any other DEFENDANT from 1999 through the
present.
The term Johan Bruyneel Sports Management is undefined, vague,
Request.
REQUEST NO. 92:
ALL DOCUMENTS RELATING TO any books RELATING TO cycling or DOPING,
including any drafts or final copies of such books and any COMMUNICATIONS
RELATING TO such books.

97
The terms any books, RELATING TO cycling, any drafts, final
copies, and such books are undefined, vague, ambiguous, overly broad,
and subject to varying interpretations; and
it calls for documents relating to any book ever written about cycling or
doping in any sport.
objections.
During meet and confer discussions, this Request was narrowed to include only
unpublished copies of Lance Armstrongs books. Stapleton does not have any documents
responsive to this Request.
This Response is not intended to and does not address any amended version of
this Request previously or currently proposed by Relators counsel during meet and confer
discussions.
REQUEST NO. 93:
ALL DOCUMENTS YOU IDENTIFY in your Initial Disclosure pursuant to Rule 26(a)(1)
of the Federal Rules of Civil Procedure.

98
YOU DEFINITION OBJECTION.
Subject to and without waiving the foregoing objections, pursuant to Fed. R. Civ.
P. 26(a)(1)(A)(ii), Stapleton produced, rather than merely identified, his documents with his
initial disclosures. Therefore, Stapleton has no documents responsive to this Request which have
not already been produced.
Subject to and without waiving the foregoing objections, Stapleton will produce a
copy of the insurance agreement under which an insurance business may be liable to satisfy all
or part of a possible judgment in the action or to indemnify or reimburse for payments made to
satisfy the judgment.
REQUEST NO. 94:
ALL DOCUMENTS YOU IDENTIFY in response to ANY interrogatories in this case.
The Request on the ground that it is premature as Stapleton has not
responded to any interrogatories in this action.

101
SERVICE LIST

VIA EMAIL ONLY
Michael D. Granston
Robert E. Chandler
David M. Finkelstein
Civil Division, Fraud Section
P. O. Box 261
Tel: (202) 514-4678
Fax: (202) 514-0280
robert.chandler@usdoj.gov
david.m.finkelstein@usdoj.gov
Counsel for Intervenor
Plaintiff United States of
America
Darrel C. Valdez
Mercedeh Momeni
United States Attorneys Office
Tel: (202) 307-2843
darrell.valdez@usdoj.gov
mercedeh.momeni@usdoj.gov
Co-Counsel for Intervenor
Plaintiff United States of
America
Paul D. Scott
Lani Anne Remick
Jon L. Praed
The Embarcadero
Pier 9, Suite 100
Tel: (415) 981-1212
Fax: (415) 981-1215
pdscott@lopds.com
laremick@lopds.com
jlpraed@lopds.com
Counsel for Relator Floyd
Landis

102
Robert D. Luskin
Benjamin D. Wood
2550 M Street, NW
Tel: (202) 457-6000
Fax: (202) 457-6315
robert.luskin@squirepb.com
benjamin.wood@squirepb.com
Counsel for Defendant Lance
Armstrong
John W. Keker
Elliot R. Peters
R. James Slaughter
Sharif E. Jacob
Tia Alexandra Sherringham
KEKER & VAN NEST LLP
633 Battery Street
San Francisco, CA 94111
Tel: (415) 391-5400
Fax: (415) 397-7188
jkeker@kvn.com
epeters@kvn.com
rslaughter@kvn.com
sjacob@kvn.com
tsherringham@kvn.com
Co-Counsel for Defendant
Lance Armstrong
Brendan P. Cullen
SULLIVAN & CROMWELL LLP
1870 Embarcadero Road
Palo Alto, CA 94303
Tel: (650) 461-5650
Fax: (650) 461-5700
Counsel for Defendants
Thomas W. Weisel and Ross
Investments, Inc.
Robert A. Sacks
Los Angeles, California 90067
Tel: (310) 712-6600
Fax: (310) 712-8800
sacksr@sullcrom.com
Co-Counsel for Defendants
Investments, Inc.

103
1700 New York Ave., NW, Suite 700
Tel: (202) 956-7500
Fax: (202) 956-7056
Co-Counsel for Defendants
Investments, Inc.
VIA EMAIL AND MAIL
Johan Bruyneel
c/o Mike Morgan
Lafone House
The Leathermarket
11-13 Weston Street
Waterloo, London SE1 3ER
mike.morgan@morgansl.com
Defendant Johan Bruyneel, in
Pro Per
VIA MAIL ONLY
Tailwind Sports Corp.
98 San Jacinto Blvd., Suite 430
Austin, TX 78701

Tailwind Sports Corp.
c/o National Registered Agents, Inc.
160 Greentree Drive, Suite 101
Dover, DE 19904

Defendant Tailwind Sports
Corp., in Pro Per
Tailwind Sports LLC
5515 Security Lane, #1103
Rockville, Maryland 20852

Tailwind Sports LLC
c/o Corporation Service Company
2711 Centerville Road, Suite 400
Wilmington, DE 19808
Defendant Tailwind Sports
LLC, in Pro Per


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