1. all questions as to competency, relevancy, materiality, privilege, and
admissibility as evidence for any purpose, at any trial or hearing in this case or in any
related or subsequent action or proceeding, if any, of any of the documents produced
hereunder or the subject matter thereof;
2. the right to object on any ground to the use of documents produced
hereunder or the subject matter thereof, at any trial or hearing in this case or in any
related or subsequent action or proceeding;
3. the right to object on any ground at any time to a demand for further
responses or document production; and
4. the right at any time to revise, supplement, correct, or add to this response.
Highbridge will limit its production subject to and without waiver of the general and
specific objections set forth herein.
GENERAL RESPONSES AND OBJECTIONS
In addition to the specific grounds for objection set forth below (the "Specific
Responses and Objections"), Highbridge responds and objects generally with respect to
each and every request as follows (the "General Responses and Objections"):
Highbridge objects to the Subpoena on the grounds that counsel serving
the subpoena lacks the authority to propound it and the arbitrator lacks authority to order
compliance with it. Highbridge's decision to produce documents in response to the
Subpoena to the parties does not waive Highbridge's objection to the Subpoena on these
grounds. By responding to this Subpoena, Highbridge assumes no obligation to
supplement its responses or to respond to any subsequent third-party subpoenas.
2
Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00061120
EFTA01581715