would include all documents created by Plaintiff in the course of the investigation preceding this case that touch explicitly or implicitly on any factual matter.

overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories.

Plaintiff further objects to this definition to the extent that it uses the undefined term "during." "During" can be construed to mean "at the time of," instead of "in the course of." To the extent that "during" is intended to mean "at the time of," Plaintiff objects to this definition as overbroad because it would call for materials unrelated to this action. Plaintiff will construe "during" to mean "in the course of."

Indeed, it has been recently held that a responding party cannot avoid complying with the express obligations of CCP § 2031.240 (b) (1) and (2), based upon a “burdensome” objection. (See Riddell, Inc. v. Superior Court (2017) 14 Cal.App.5th 755, 722.)

If there aren’t any actual documents in the demanded category, which are in the custody, possession or control of the responding party, then simply do not object. The responding party should only “object” if there are actual responsive documents in such custody, possession or control, and which the responding party doesn’t want to produce

CCP § 2031.240 (b) (1) and (2) should be self-evident. It tells the responding party what type of documents you have that you don’t want to produce,

The events of the past months took a significant toll on workers in the country. In the days after restrictions were lifted, Reuters reported thousands of workers left Ho Chi Minh City, where nearly half of reported COVID-19 cases took place. And now, manufacturers in Vietnam fear additional labor shortages despite a reopened economy.

he shipment of product that is heading to US backers has reached the port, and we are now at the mercy of the steamship line and port.  The best information we have is that it should be unloaded within the next 2-3 days and sent to our warehouse.  We currently expect it to be at our warehouse on 3/21-3/23, and sent to the shipper.  Because these orders have already been picked, packed and labeled, the turn around time there will be quick.  Once all the orders are with the shipper, it should only take your order 3-5 days to get to your address.

Sorry that we missed updating last week.  We were going back and forth with our freight forwarder on the shipments and didn't get any actionable/reliable information from them till the weekend.  So here is the latest information. US orders: In the past couple of updates I have ended with the warning, that we are in the point where we should expect to see delays.  We have been seeing this with other shipments, and I didn't want you to be surprised by another delay.  Well, as expected, last week we were told that the container was delayed, but fortunately it has only been delayed by 2 weeks.  (Delays are never fortunate, but I say "fortunately", because we have seen delays of up to a month at this point on our other shipments).  The expected date for the products to be delivered was today 2/28, but we are being told now that they will arrive at port on 3/11.  As we said in previous updates, from the day it arrives at port we expect it to take 1 week to get to our warehouse, then it should get from the warehouse to your door in 5 days.  As you guys know, these delays have been happening across all industries and while the products are being imported, we have very little control or ability to impact the delivery time.

International orders have also seen a similar delay.  We were expecting to see the international shipment hit port on 3/21, but we are now expecting to see it hit port 13 days later on 4/3.  From there it will be taken off the boat and put onto a train, and then shipped by rail to our warehouse.  Based on those processes taking up to 3 weeks, we are expecting to have these orders shipped out around the end of April.   Which means that this delay has pushed back the delivery of international orders by about 2-3 weeks.  Like I said above, As you guys know, these delays have been happening across all industries and while the products are being imported, we have very little control or ability to impact the delivery time.  We are at the mercy of the freight forwarder and global supply chain issues.  So as I have said in the past my goal is to be transparent and keep you guys informed.  We will do our best to continue to do this.

So I guess no news is good news, right!

For international backers,  this shipment delivery date seems to keep shifting, but we working on new method to take it form the port to our warehouse that could help us keep it on track.  We're doing some testing with this shipping method with current inventory so we can understand this new shipping method before utilizing it on your orders.

We've spoken with our freight forwarders, and they mentioned that there may be a 1 week delay to get the orders to the port for US orders, but we are trying to see if we can still deliver to the port on 2/21.  We will work on this during this upcoming week and let you know what we find out.

You may be wondering why we are shipping it to a port in Mexico.  We selected this port cause it has a lot less congestion compared to other ports on the west coast, and we actually have warehousing facilities in Mexico.  So this will not be our first time working on order fulfillment through Mexico.   Our current information tells us that the shipment is set to arrive at port on 2/13, and get to our warehouse on 2/21.  From there we will expect to have orders handed over to UPS by 2/28, then they should be in your hands within 3-5 business days, so no later than 3/7.

For international backers, your products are also on the ocean, and expected to get to the warehouse on 3/21.  These are shipping to our Canadian warehouse.  From there, they will be picked packed and shipped from our warehouse by early April.

we have never experienced these types of supply chain issues since starting our business in 2014.

We chose to have the containers shipped through a port with less congestion and based on the booking we should have met our promised timeline.  And up until now, we were being informed that everything was still on schedule.  However, we just learned that there was a glitch in our freight forwarders system and dashboards that showed the shipment was on time, when in reality, due to container shortages, the shipment never shipped from Vietnam.  Because freight forwarders are experiencing so many new problems, their systems are not designed to catch and communicate all these issues as they normally would.  So, we went undetected by their team until now ☹. Shipment from Vietnam to USA—(Jan 20th)  We have now been informed that our shipment from Vietnam should be leaving today and will be landing at the port on 2/20. Shipment from USA warehouse to Backers--If we receive the products on 2/20, our current information tells us that we should have the orders to our warehouse and shipped out one week after that date (2/27).  It will then take roughly 5 days to get our US customers (3/4).  So, our current expectations are for Backers to receive their products between March 4th to March 12th. As communicated in our last update, our international customers should expect to receive their product one month later.

As a way to apologize for these issues and express a sincere “Thank You” for your patience, we will be sending you $30 that can be used on NOMATIC.com. No strings attached, just $30 to spend on whatever you want.