Professional Documents
Culture Documents
A.
Armstrong has failed to respond to the vast majority of relators First Set of
Requests for Admissions (RFAs). The RFAs request that Armstrong admit or deny
using anabolic steroids, erythropoietin (EPO), human growth hormone (HgH), blood
doping, corticosteroids, or any other prohibited substance or method in each race he is
believed to have raced in from 1998 to 2004. See Scott Decl., Ex. A, Armstrongs
Responses to Relators RFAs. They also ask him to admit or deny that he knew each
such substance or method was prohibited by the UCI or the IOC on a year-by-year basis.1
Id. Due to the number of PEDs taken by Armstrong and the number of races in which he
is believed to have raced for USPS, there are 435 RFAs, but Armstrong has only
responded to 16. Id. In meet and confer discussions, Armstrong has contended that the
number of requests is unduly burdensome. This objection, however, along with the other
boilerplate objections included in Armstrongs responses, is without merit.
A party responding to requests for admission must admit or specifically deny
the matter stated, or -- after making a reasonable inquiry -- may assert lack of
knowledge or information as a reason for failing to admit or deny. Fed. R. Civ. P.
36(a)(4). Here, Armstrong has merely objected to the RFAs, without even representing
that he made any reasonable inquiry to attempt to answer them. Armstrongs
burdensomeness objection is thus not justified, and Armstrong should be ordered to
answer the RFAs. Tequila Centinela, S.A. de C.V. v. Bacardi & Co., 247 F.R.D. 198, 202
(D.D.C. 2008) (Unless the court finds an objection justified, it must order that an answer
be served. The court may order either that the matter is admitted or that an amended
answer be served.) (citing Fed. R. Civ. P. 36(a)(6)).
A party resisting discovery bears the burden to show why discovery should be
denied. Tequila Centinela, S.A. de C.V. v. Bacardi & Co., 242 F.R.D. 1, 8 (D.D.C.
2007). When objecting on grounds of burdensomeness, the objecting party must make a
specific, detailed showing of how the discovery is burdensome. Id. [T]he objector
1
There are a few specific additional RFAs inquiring into Armstrongs use of
Actovegin, an extract of calfs blood.
1
must do more than just state the objection, the objector must submit affidavits or offer
evidence which reveals the nature of the burden. Id. (citing Chubb Integrated Systems
Ltd. v. National Bank of Washington, 103 F.R.D. 52, 59-60 (D.D.C. 1984)). Where no
such showing is made, the court must overrule the objection. Id; see also Alexander v.
FBI, 194 F.R.D. 299, 302 (D.D.C. 2000) (unreasonably cumulative and duplicative
objection overruled where objecting party failed to identify the duplicative discovery).
Here, Armstrong has made no showing at all as to why he cannot state whether or
not he doped during each of the events in which he raced under the banner of the USPS.
The mere fact that there are a large number of requests for admission is an insufficient
basis for objection. The large number here is necessary to cover each of the events in
which Armstrong raced for the USPS (approximately five to ten events in each of the
seven years 1998 through 2004), and because over time Armstrong used multiple
performance enhancing drugs. Numerous courts have ordered responses to similar
numbers of RFAs when justified by the facts of the case.2
Armstrongs counsel frequently argues that Armstrongs use of performance
enhancing substances is not disputed, but the reality is that Armstrongs admissions to
date have been carefully orchestrated and have not included relevant details. Moreover,
Armstrong has frequently sought to minimize his doping in his testimony and otherwise.
Plaintiffs should be entitled to counter these types of arguments by showing the extent of
Armstrongs doping with particularity. Moreover, the number of races in which
2
See, e.g., Layne Christensen Co. v. Purolite Co., No. 09-2381-JWL-GLR, 2011
WL 381611, at *3-7 (D. Kan. Jan. 25, 2011) (277 RFAs to one defendant and 329 to
another not excessive where plaintiffs had offered no evidence, by affidavit or
otherwise, to support their suggestion that the requests do create an undue burden);
Sommerfield v. City of Chicago, 251 F.R.D. 353, 355 n.3 (N.D. Ill. 2007) (177 RFAs (or
234 counting subparts) not per se excessive although some failed for other reasons);
Heartland Surgical Specialty Hosp., LLC v. Midwest Div., Inc ., No. 052164MLB
DWB, 2007 WL 3171768, at *2-3 (D. Kan. Oct. 29, 2007) (total of 1351 RFAs served by
multiple defendants not unduly burdensome given the complex allegations and fact that
$121 million in damages was asserted); see also Wigler v. Elec. Data Sys. Corp., 108
F.R.D. 204, 206 (D. Md. 1985) (Where a case is particularly complex, a large number of
requests for admission may be justifiable.).
2
Armstrong doped while riding for USPS, along with the substances he used, goes to the
materiality and number of breaches of the Sponsorship Agreements. Responses to the
RFAs will narrow the issues and reduce the time needed on these topics at trial.
B.
On or about July 22, 2015, relator requested that W&C prioritize production of a
subset of emails sent to non-privileged third parties. Scott Decl. at 3. W&C agreed and
identified 318 such documents that it determined were responsive and delivered those
documents to Armstrong. Id. On August 10, 2015, relator received a production from
Armstrong which combined the foregoing W&C production and another production into
one much larger production, so that it was impossible to identify the prioritized
documents and/or whether any had been withheld. Id. at 4. Relator objected and after
considerable back and forth, Armstrong provided the W&C Bates numbers for the
prioritized production, which allowed relator to see that 10 pages of documents had, in
fact, been withheld by Armstrong. Id. Armstrongs counsel has claimed that the
withheld documents were not shared with third parties, but that contention is contradicted
by W&Cs representations regarding the search criteria for the prioritized production. Id.
at 3. In light of the foregoing, relator seeks the Bates numbers of the withheld ten pages
and reliable confirmation that the ten pages have not been shared with third parties.
Relator also respectfully requests that Armstrong be required to produce the
remaining W&C documents. W&C has made three additional productions of documents
since Armstrongs last production on August 10th, for a total of five productions. Id. at
5. It was only on Saturday September 19, 2015, after relator had advised Armstrongs
counsel of his plans to contact the Court, that Armstrong finally produced W&Cs third
and fourth productions to relator. Relator has still not received W&Cs fifth production.
C.
against Armstrong . . . . ECF No. 366, Order of July 1, 2015. Relator and his criminal
defense counsel Wilson, Sonsini subsequently produced a large volume of documents
pertaining to the FFF and the criminal proceedings in the Southern District of California
involving Mr. Landis. Those documents included redacted copies of lists of donors to the
FFF. Armstrong now seeks unredacted copies of the donor lists.
As a threshold matter, the names of the donors to the FFF are manifestly not
relevant to the merits in this case. Moreover, relator has already admitted in writing that
he made false representations to the donors. Accordingly, disclosure of the previously
undisclosed identities of the non-party donors and their financial information would not
be proportional to the needs of the case. Fed. R. Civ. P. 26(b)(1).
Separately, Armstrongs request also runs counter to the confidential treatment of
the donor names by the District Court for the Southern District of California. During the
Landis criminal proceeding and through the present, the names and contributions of
donors have been specifically treated as confidential by the USAO and the Court. The
Deferred Prosecution Agreement (DPA) provided for the donors continued anonymity,
referring to them as certain donors and requiring that A confidential list of donors will
be provided to the Clerk of the Court within 90 days from the time this Agreement is
filed. See ECF No. 225-15, DPA, section VII. The District Courts subsequent Order
incorporated the DPA by reference and further provided for confidential notification to
the Court Clerk of the identity of any individuals who did not wish to receive restitution.
Scott Decl. 6, Ex. B.
In light of the foregoing, it is not sufficient to say that there is a protective order
available in this case, for neither the United States nor the District Court for the Southern
District of California has advised relator that the information at issue should be made
available to Mr. Armstrong or the other defendants in this case, and the third parties
whose privacy interests are at stake have not had an opportunity to assert their objections.
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
California State Bar No. 189889
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
No. 1:10-cv-00976-CRC
the Law Offices of Paul D. Scott, P.C., is counsel for relator Floyd Landis. I am
admitted pro hac vice to practice before this Court in the above-titled action.
2.
On or about July 22, 2015, relator requested that W&C prioritize its
production of a subset of emails that were sent to non-privileged third parties. W&C
agreed, and counsel for W&C described these documents as follows in a July 23,
2015 email to relator:
Armstrong which combined the foregoing production with another separate W&C
production into one much larger production so that it was impossible to identify the
prioritized documents and/or whether any had been withheld. Relator objected and
after considerable back and forth, Armstrong provided the W&C Bates numbers for
the prioritized production, which allowed relator to see that 10 pages of documents
had, in fact, been withheld.
5.
28, and September 15 - since Armstrongs last production of W&C documents to the
relator on August 10th, for a total of five productions. It was only on Saturday
September 19, 2015, however, after relator had advised Armstrongs counsel of his
plans to contact the Court, that Armstrong finally produced documents from the third
and fourth W&C productions. Relator has still not received the documents produced
in W&Cs fifth production.
6.
the matter United States v. Landis, Case No. 12CR3481-BEN (S.D. Cal.) filed on
March 8, 2013.
I declare under penalty of perjury under the laws of the United States that the
foregoing is true and correct. Executed this 21st day of September, 2015.
/s/
PAUL D. SCOTT
v.
TAILWIND SPORTS CORP., et al.,
Defendants.
979791
Pursuant to Rules 26 and 35 of the Federal Rules of Civil Procedure, defendant Lance
Armstrong (Armstrong), through his undersigned counsel, hereby responds to the relators First
Set of Requests for Admission.
GENERAL OBJECTIONS
1.
Armstrong objects that the requests for admission are disproportionate to the
needs of the case, unreasonably cumulative and duplicative, and burdensome. Fed. R. Civ. Proc.
26(b)(1), (b)(2)(C). The relator has served four-hundred thirty-five requests for admission
seeking information that is duplicative of prior request to Armstrong and already within his
possession. Courts routinely disallow requests for admission that run into the hundreds on the
grounds that they are abusive, unreasonable, and oppressive. Tamas v. Family Video Movie
Club, Inc., 301 F.R.D. 346, 346 (N.D. Ill. 2014).
2.
Armstrongs responses are based upon a reasonable inquiry and his current
knowledge.
3.
Armstrong objects to each request to the extent that it seeks information that is
protected by the attorney-client privilege, work product doctrine, joint defense privilege,
common interest privilege, and/or any other applicable privilege. Any disclosure of such
protected or privileged information is inadvertent and not intended to waive those privileges or
protections.
4.
Armstrong objects to each request to the extent that it purports to require him to
Armstrong objects to the each request to the extent that it seeks information
obtainable by the relator from other sources that can provide the requested information more
conveniently, more easily and less expensively than can Armstrong.
1
979791
6.
a request asks for all, every or any information on a particular subject, Armstrong, in responding
to such request, will undertake to supply information known to him at the time of the response
after a reasonable inquiry, and will not undertake any obligation, express or implied, to represent
that the response includes all, every or any of the information that may exist.
7.
Armstrongs responses to any request are not intended to and shall not constitute
an admission or agreement that any matter inquired into or any response provided is in any way
relevant to any claim or issue in this action. Armstrong expressly reserves all evidentiary
objections to the time of trial.
OBJECTIONS TO INSTRUCTIONS
1.
obligation beyond the requirements of Federal Rule of Civil Procedure 26(e) or inconsistent with
Federal Rule of Civil Procedure 36(b).
2.
incomprehensible.
OBJECTIONS TO DEFINITIONS
1.
overbroad. Armstrong understands Blood Doping to mean the transfusion of ones own
previously-extracted blood.
4.
vague, compound, overbroad, burdensome, superfluous, and seeking irrelevant information that
2
979791
is not proportional to the needs of the case. Armstrong also objects that the definition does not
incorporate a time frame, and is therefore overbroad, burdensome, and oppressive.
5.
ambiguous. Furthermore, as defined, it renders each request that uses the phrase compound.
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 3:
Admit that the use of anabolic steroids was prohibited by the rules of the IOC in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 3:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 4:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the IOC
in 1998.
4
979791
5
979791
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 6:
Admit that you used anabolic steroids in connection with the Tour de France in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 6:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Denied.
REQUEST FOR ADMISSION NO. 7:
Admit that you used anabolic steroids in connection with the Clasica San Sebastian in
1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 7:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
6
979791
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 8:
Admit that you used anabolic steroids in connection with the Tour of Spain in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 8:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 9:
Admit that you used anabolic steroids in connection with the Zuri Metgette in 1998.
7
979791
8
979791
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 11:
Admit that you used anabolic steroids in connection with the Paris Tours in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 11:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 12:
Admit that the use of EPO was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 12:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
9
979791
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 13:
Admit that you knew the use of EPO was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 13:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 14:
Admit that the use of EPO was prohibited by the rules of the IOC in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 14:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
10
979791
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
REQUEST FOR ADMISSION NO. 15:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 15:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: After a reasonable inquiry, Armstrong lacks sufficient recollection,
knowledge, and information to respond, and on that basis denies.
11
979791
12
979791
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Denied.
REQUEST FOR ADMISSION NO. 18:
Admit that you used EPO in connection with the Clasica San Sebastian in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 18:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 19:
Admit that you used EPO in connection with the Tour of Spain in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 19:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
13
979791
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 22:
Admit that you used EPO in connection with the Paris Tours in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 22:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 23:
Admit that the use of HGH was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 23:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
15
979791
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 24:
Admit that you knew the use of HGH was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 24:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, seeks irrelevant information,
and is not proportional to the needs of the case. Armstrong further objects to this request to the
extent it seeks information that is not within Armstrongs possession, custody or control.
Armstrong further specifically objects to this request to the extent that it seeks information
protected by the attorney-client privilege, attorney work product doctrine, or any other applicable
privilege or immunity. Armstrong objects to this request to the extent it is unreasonably
cumulative or duplicative of other requests.
Without waiving and subject to the foregoing general and specific objections, Armstrong
responds as follows: Admitted.
REQUEST FOR ADMISSION NO. 25:
Admit that the use of HGH was prohibited by the rules of the IOC in 1998.
16
979791
17
979791
18
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 29:
Admit that you used HGH in connection with the Clasica San Sebastian in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 29:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 30:
Admit that you used HGH in connection with the Tour of Spain in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 30:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
19
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 33:
Admit that you used HGH in connection with the Paris Tours in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 33:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 34:
Admit that Blood Doping was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 34:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
21
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 35:
Admit that you knew Blood Doping was prohibited by the rules of the UCI in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 35:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 36:
Admit that Blood Doping was prohibited by the rules of the IOC in 1998.
22
979791
23
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 40:
Admit that you engaged in the practice of Blood Doping in connection with the Clasica
San Sebastian in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 40:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 41:
Admit that you engaged in the practice of Blood Doping in connection with the Tour of
Spain in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 41:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
25
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 42:
Admit that you engaged in the practice of Blood Doping in connection with the Zuri
Metgette in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 42:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 43:
Admit that you engaged in the practice of Blood Doping in connection with the Tour of
Luxumbourg in 1998.
26
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 47:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 47:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 48:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 48:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
29
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 49:
Admit that you used corticosteroids in connection with professional cycling events in
1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 49:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 50:
Admit that you used corticosteroids in connection with the Tour de France in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 50:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
30
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 51:
Admit that you used corticosteroids in connection with the Clasica San Sebastian in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 51:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 52:
Admit that you used corticosteroids in connection with the Tour of Spain in 1998.
31
979791
32
979791
33
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 56:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with professional cycling events in
1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 56:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 57:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de France in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 57:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
34
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 58:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Circuit de la Sarthe in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 58:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 59:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Criterium Dauphine in 1998.
35
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 65:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Paris Tours in 1998.
RESPONSE TO REQUEST FOR ADMISSION NO. 65:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 66:
Admit that the use of anabolic steroids was prohibited by the rules of the UCI in 1999.
39
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 70:
Admit that you used anabolic steroids in connection with professional cycling events in
1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 70:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 71:
Admit that you used anabolic steroids in connection with the Tour de France in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 71:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
42
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 72:
Admit that you used anabolic steroids in connection with the Circuit de la Sarthe in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 72:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 73:
Admit that you used anabolic steroids in connection with the Criterium Dauphine in
1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 73:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
43
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 74:
Admit that you used anabolic steroids in connection with the Route du Sud in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 74:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 75:
Admit that you used anabolic steroids in connection with the Amstel Gold race in 1999.
44
979791
45
979791
46
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 79:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 79:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 80:
Admit that you used EPO in connection with professional cycling events in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 80:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
47
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 83:
Admit that you used EPO in connection with the Criterium Dauphine in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 83:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 84:
Admit that you used EPO in connection with the Route du Sud in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 84:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
49
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 85:
Admit that you used EPO in connection with the Amstel Gold race in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 85:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 86:
Admit that the use of HGH was prohibited by the rules of the UCI in 1999.
50
979791
51
979791
52
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 90:
Admit that you used HGH in connection with professional cycling events in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 90:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 91:
Admit that you used HGH in connection with the Tour de France in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 91:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
53
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 94:
Admit that you used HGH in connection with the Route du Sud in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 94:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 95:
Admit that you used HGH in connection with the Amstel Gold race in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 95:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
55
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 96:
Admit that Blood Doping was prohibited by the rules of the UCI in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 96:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 97:
Admit that you knew Blood Doping was prohibited by the rules of the UCI in 1999.
56
979791
57
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 101:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 101:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 102:
Admit that you engaged in the practice of blood doping in connection with the Circuit de
la Sarthe in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 102:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
59
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 103:
Admit that you engaged in the practice of blood doping in connection with the Criterium
Dauphine in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 103:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 104:
Admit that you engaged in the practice of blood doping in connection with the Route du
Sud in 1999.
60
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 108:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 108:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 109:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 109:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
63
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 110:
Admit that you used corticosteroids in connection with professional cycling events in
1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 110:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 111:
Admit that you used corticosteroids in connection with the Tour de France in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 111:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
64
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 112:
Admit that you used corticosteroids in connection with the Circuit de la Sarthe in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 112:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 113:
Admit that you used corticosteroids in connection with the Criterium Dauphine in 1999.
65
979791
66
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 117:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de France in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 117:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 118:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Circuit de la Sarthe in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 118:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
68
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 119:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Criterium Dauphine in 1999.
RESPONSE TO REQUEST FOR ADMISSION NO. 119:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 120:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Route du Sud in 1999.
69
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 124:
Admit that the use of anabolic steroids was prohibited by the rules of the IOC in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 124:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 125:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the IOC
in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 125:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
72
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 126:
Admit that you used anabolic steroids in connection with professional cycling events in
2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 126:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 127:
Admit that you used anabolic steroids in connection with the Tour de France in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 127:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
73
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 128:
Admit that you used anabolic steroids in connection with the GP des Nations in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 128:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 129:
Admit that you used anabolic steroids in connection with the Criterium Dauphine in
2000.
74
979791
75
979791
76
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 133:
Admit that you used anabolic steroids in connection with the Zuri Metgette in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 133:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 134:
Admit that you used anabolic steroids in connection with the GP Argoive in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 134:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
77
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 137:
Admit that the use of EPO was prohibited by the rules of the IOC in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 137:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 138:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 138:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
79
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 139:
Admit that you used EPO in connection with professional cycling events in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 139:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 140:
Admit that you used EPO in connection with the Tour de France in 2000.
80
979791
81
979791
82
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 144:
Admit that you used EPO in connection with the GP Eddy Merckx in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 144:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 145:
Admit that you used EPO in connection with the Olympics in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 145:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
83
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 148:
Admit that the use of HGH was prohibited by the rules of the UCI in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 148:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 149:
Admit that you knew the use of HGH was prohibited by the rules of the UCI in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 149:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
85
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 150:
Admit that the use of HGH was prohibited by the rules of the IOC in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 150:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 151:
Admit that you knew the use of HGH was prohibited by the rules of the IOC in 2000.
86
979791
87
979791
88
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 155:
Admit that you used HGH in connection with the Criterium Dauphinee in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 155:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 156:
Admit that you used HGH in connection with the Paris Cambert in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 156:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
89
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 159:
Admit that you used HGH in connection with the Zuri Metgette in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 159:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 160:
Admit that you used HGH in connection with the GP Argoive in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 160:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
91
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 161:
Admit that Blood Doping was prohibited by the rules of the UCI in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 161:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 162:
Admit that you knew Blood Doping was prohibited by the rules of the UCI in 2000.
92
979791
93
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 166:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 166:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 167:
Admit that you engaged in the practice of Blood Doping in connection with the GP des
Nations in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 167:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
95
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 168:
Admit that you engaged in the practice of Blood Doping in connection with the Criterium
Dauphinee in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 168:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 169:
Admit that you engaged in the practice of Blood Doping in connection with the Paris
Cambert in 2000.
96
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 173:
Admit that you engaged in the practice of Blood Doping in connection with the GP
Argoive in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 173:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 174:
Admit that the use of corticosteroids was prohibited by the rules of the UCI in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 174:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
99
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 175:
Admit that you knew the use of corticosteroids was prohibited by the rules of the UCI in
2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 175:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 176:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 176:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
100
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 177:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 177:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
101
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 180:
Admit that you used corticosteroids in connection with the GP des Nations in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 180:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 181:
Admit that you used corticosteroids in connection with the Criterium Dauphine in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 181:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
103
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 184:
Admit that you used corticosteroids in connection with the Olympics in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 184:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 185:
Admit that you used corticosteroids in connection with the Zuri Metgette in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 185:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
105
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 186:
Admit that you used corticosteroids in connection with the GP Argoive in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 186:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 187:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with professional cycling events in
2000.
106
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 191:
Admit that, at the time you used Actovegin in 2000, you knew that Actovegin consisted
of an extract of bovine calf blood.
RESPONSE TO REQUEST FOR ADMISSION NO. 191:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 192:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the GP des Nations in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 192:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
109
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 193:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Criterium Dauphinee in
2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 193:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 194:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Paris Cambert in 2000.
110
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 198:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the GP Argoive in 2000.
RESPONSE TO REQUEST FOR ADMISSION NO. 198:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 199:
Admit that the use of anabolic steroids was prohibited by the rules of the UCI in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 199:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
113
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 200:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the UCI
in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 200:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 201:
Admit that the use of anabolic steroids was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 201:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
114
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 202:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the IOC
in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 202:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
115
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 205:
Admit that you used anabolic steroids in connection with the Paris Cambert in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 205:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 206:
Admit that you used anabolic steroids in connection with the Tour de Suisse in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 206:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
117
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 209:
Admit that you knew the use of EPO was prohibited by the rules of the UCI in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 209:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 210:
Admit that the use of EPO was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 210:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
119
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 211:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 211:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 212:
Admit that you used EPO in connection with professional cycling events in 2001.
120
979791
121
979791
122
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 216:
Admit that you used EPO in connection with the Amstel Gold race in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 216:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 217:
Admit that the use of HGH was prohibited by the rules of the UCI in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 217:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
123
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 220:
Admit that you knew the use of HGH was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 220:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 221:
Admit that you used HGH in connection with professional cycling events in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 221:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
125
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 222:
Admit that you used HGH in connection with the Tour de France in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 222:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 223:
Admit that you used HGH in connection with the Paris Cambert in 2001.
126
979791
127
979791
128
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 227:
Admit that you knew Blood Doping was prohibited by the rules of the UCI in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 227:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 228:
Admit that Blood Doping was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 228:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
129
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 231:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 231:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 232:
Admit that you engaged in the practice of Blood Doping in connection with the Paris
Cambert in 2001.
131
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 236:
Admit that you knew the use of corticosteroids was prohibited by the rules of the UCI in
2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 236:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 237:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 237:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
134
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 238:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 238:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 239:
Admit that you used corticosteroids in connection with professional cycling events in
2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 239:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
135
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 240:
Admit that you used corticosteroids in connection with the Tour de France in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 240:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 241:
Admit that you used corticosteroids in connection with the Paris Cambert in 2001.
136
979791
137
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 245:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de France in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 245:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 246:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Paris Cambert in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 246:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
139
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 247:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de Suisse in 2001.
RESPONSE TO REQUEST FOR ADMISSION NO. 247:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 248:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Amstel Gold race in 2001.
140
979791
141
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 252:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the IOC
in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 252:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 253:
Admit that you used anabolic steroids in connection with professional cycling events in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 253:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
143
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 254:
Admit that you used anabolic steroids in connection with the Tour de France in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 254:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 255:
Admit that you used anabolic steroids in connection with the GP Midi Libre in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 255:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
144
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 256:
Admit that you used anabolic steroids in connection with the Criterium Dauphine in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 256:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 257:
Admit that you used anabolic steroids in connection with the Paris Cambert in 2002.
145
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 261:
Admit that you used anabolic steroids in connection with the Ronde Van Vlaanderen in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 261:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 262:
Admit that you used anabolic steroids in connection with the Clasica San Sebastian in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 262:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
148
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 263:
Admit that the use of EPO was prohibited by the rules of the UCI in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 263:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 264:
Admit that you knew the use of EPO was prohibited by the rules of the UCI in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 264:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
149
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 265:
Admit that the use of EPO was prohibited by the rules of the IOC in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 265:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 266:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 2002.
150
979791
151
979791
152
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 270:
Admit that you used EPO in connection with the Criterium Dauphine in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 270:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 271:
Admit that you used EPO in connection with the Paris Cambert in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 271:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
153
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 274:
Admit that you used EPO in connection with the Luik Bastenaken Luik in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 274:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 275:
Admit that you used EPO in connection with the Ronde Van Vlaanderen in 2002
RESPONSE TO REQUEST FOR ADMISSION NO. 275:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
155
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 276:
Admit that you used EPO in connection with the Clasica San Sebastian in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 276:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 277:
Admit that you used HGH in connection with the Tour de France in 2002.
156
979791
157
979791
158
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 281:
Admit that the use of HGH was prohibited by the rules of the UCI in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 281:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 282:
Admit that you used HGH in connection with professional cycling events in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 282:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
159
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 285:
Admit that you used HGH in connection with the Criterium Dauphine in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 285:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 286:
Admit that you used HGH in connection with the Paris Cambert in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 286:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
161
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 287:
Admit that you used HGH in connection with the Profronde van Stiphout in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 287:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 288:
Admit that you used HGH in connection with the Amstel Gold race in 2002.
162
979791
163
979791
164
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 292:
Admit that Blood Doping was prohibited by the rules of the UCI in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 292:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 293:
Admit that you knew Blood Doping was prohibited by the rules of the UCI in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 293:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
165
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 296:
Admit that you engaged in the practice of Blood Doping in connection with professional
cycling events in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 296:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 297:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 2002.
167
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 301:
Admit that you engaged in the practice of Blood Doping in connection with the Profronde
van Stiphout in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 301:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 302:
Admit that you engaged in the practice of Blood Doping in connection with the Amstel
Gold race in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 302:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
170
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 303:
Admit that you engaged in the practice of Blood Doping in connection with the Luik
Bastenaken Luik in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 303:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 304:
Admit that you engaged in the practice of Blood Doping in connection with the Ronde
Van Vlaanderen in 2002.
171
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 308:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 308:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 309:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 309:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
174
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 310:
Admit that you used corticosteroids in connection with professional cycling events in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 310:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 311:
Admit that you used corticosteroids in connection with the Tour de France in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 311:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
175
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 312:
Admit that you used corticosteroids in connection with the GP Midi Libre in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 312:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 313:
Admit that you used corticosteroids in connection with the Criterium Dauphine in 2002.
176
979791
177
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 317:
Admit that you used corticosteroids in connection with the Luik Bastenaken Luik in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 317:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 318:
Admit that you used corticosteroids in connection with the Ronde Van Vlaanderen in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 318:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
179
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 319:
Admit that you used corticosteroids in connection with the Clasica San Sebastian in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 319:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 320:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with professional cycling events in
2002.
180
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 324:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Paris Cambert in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 324:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 325:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Profronde van Stiphout in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 325:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
183
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 326:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Amstel Gold race in 2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 326:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
184
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 329:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Clasica San Sebastian in
2002.
RESPONSE TO REQUEST FOR ADMISSION NO. 329:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 330:
Admit that the use of anabolic steroids was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 330:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
186
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 331:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the UCI
in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 331:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 332:
Admit that the use of anabolic steroids was prohibited by the rules of the IOC in 2003.
187
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 336:
Admit that you used anabolic steroids in connection with the Criterium Dauphine in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 336:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 337:
Admit that you used anabolic steroids in connection with the Luik Bastenaken Luik in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 337:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
190
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 338:
Admit that you used anabolic steroids in connection with the Amstel Gold race in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 338:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 339:
Admit that the use of EPO was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 339:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
191
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 340:
Admit that you knew the use of EPO was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 340:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 341:
Admit that the use of EPO was prohibited by the rules of the IOC in 2003.
192
979791
193
979791
194
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 345:
Admit that you used EPO in connection with the Criterium Dauphine in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 345:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 346:
Admit that you used EPO in connection with the Luik Bastenaken Luik in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 346:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
195
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 349:
Admit that you knew the use of HGH was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 349:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 350:
Admit that the use of HGH was prohibited by the rules of the IOC in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 350:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
197
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 351:
Admit that you knew the use of HGH was prohibited by the rules of the IOC in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 351:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 352:
Admit that you used HGH in connection with professional cycling events in 2003.
198
979791
199
979791
200
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 356:
Admit that you used HGH in connection with the Amstel Gold race in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 356:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 357:
Admit that Blood Doping was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 357:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
201
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 360:
Admit that you knew Blood Doping was prohibited by the rules of the IOC in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 360:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 361:
Admit that you engaged in the practice of Blood Doping in connection with professional
cycling events in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 361:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
203
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 362:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 362:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
204
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 365:
Admit that you engaged in the practice of Blood Doping in connection with the Amstel
Gold race in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 365:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 366:
Admit that the use of corticosteroids was prohibited by the rules of the UCI in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 366:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
206
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 367:
Admit that you knew the use of corticosteroids was prohibited by the rules of the UCI in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 367:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 368:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 368:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
207
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 369:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 369:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
208
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 372:
Admit that you used corticosteroids in connection with the Criterium Dauphine in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 372:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 373:
Admit that you used corticosteroids in connection with the Luik Bastenaken Luik in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 373:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
210
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 374:
Admit that you used corticosteroids in connection with the Amstel Gold race in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 374:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 375:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with professional cycling events in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 375:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
211
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 376:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de France in 2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 376:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
212
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 379:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Luik Bastenaken Luik in
2003.
RESPONSE TO REQUEST FOR ADMISSION NO. 379:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 380:
Admit that the use of anabolic steroids was prohibited by the rules of the UCI in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 380:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
214
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 381:
Admit that you knew the use of anabolic steroids was prohibited by the rules of the UCI
in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 381:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 382:
Admit that the use of anabolic steroids was prohibited by the rules of the IOC in 2004.
215
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 386:
Admit that you used anabolic steroids in connection with the Profronde van Stiphout in
2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 386:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 387:
Admit that you used anabolic steroids in connection with the GP Midi Libre in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 387:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
218
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 388:
Admit that you used anabolic steroids in connection with the Tour of Georgia in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 388:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 389:
Admit that you used anabolic steroids in connection with the Volta Algarve in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 389:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
219
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 390:
Admit that the use of EPO was prohibited by the rules of the UCI in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 390:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 391:
Admit that you knew the use of EPO was prohibited by the rules of the UCI in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 391:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
220
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 392:
Admit that the use of EPO was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 392:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 393:
Admit that you knew the use of EPO was prohibited by the rules of the IOC in 2004.
221
979791
222
979791
223
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 397:
Admit that you used EPO in connection with the GP Midi Libre in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 397:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 398:
Admit that you used EPO in connection with the Tour of Georgia in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 398:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
224
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 401:
Admit that you knew the use of HGH was prohibited by the rules of the UCI in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 401:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 402:
Admit that the use of HGH was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 402:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
226
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 403:
Admit that you knew the use of HGH was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 403:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 404:
Admit that you used HGH in connection with professional cycling events in 2004.
227
979791
228
979791
229
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 408:
Admit that you used HGH in connection with the Tour of Georgia in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 408:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 409:
Admit that you used HGH in connection with the Volta Algarve in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 409:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
230
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 412:
Admit that Blood Doping was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 412:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 413:
Admit that you knew Blood Doping was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 413:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
232
979791
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 414:
Admit that you engaged in the practice of Blood Doping in connection with professional
cycling events in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 414:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 415:
Admit that you engaged in the practice of Blood Doping in connection with the Tour de
France in 2004.
233
979791
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 419:
Admit that you engaged in the practice of Blood Doping in connection with the Volta
Algarve in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 419:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 420:
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 421:
Admit that you knew the use of corticosteroids was prohibited by the rules of the UCI in
2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 421:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 422:
Admit that the use of corticosteroids was prohibited by the rules of the IOC in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 422:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
237
979791
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 423:
Admit that you knew the use of corticosteroids was prohibited by the rules of the IOC in
2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 423:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
238
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 426:
Admit that you used corticosteroids in connection with the Profronde van Stiphout in
2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 426:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 427:
Admit that you used corticosteroids in connection with the GP Midi Libre in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 427:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
240
979791
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 428:
Admit that you used corticosteroids in connection with the Tour of Georgia in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 428:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 429:
Admit that you used corticosteroids in connection with the Volta Algarve in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 429:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
241
979791
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 430:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with professional cycling events in
2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 430:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 431:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour de France in 2004.
242
979791
243
979791
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 433:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the GP Midi Libre in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 433:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 434:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Tour of Georgia in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 434:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
244
979791
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
REQUEST FOR ADMISSION NO. 435:
Admit that you used Prohibited Substances or Methods other than anabolic steroids,
corticosteroids, EPO, HGH or Blood Doping in connection with the Volta Algarve in 2004.
RESPONSE TO REQUEST FOR ADMISSION NO. 435:
Armstrong incorporates his General Objections, Objections to Instructions, and
Objections to Definitions, above as though set forth in this response. Armstrong objects to this
request on the grounds that it is overly broad, unduly burdensome, and seeks irrelevant
information. Armstrong further objects to this request to the extent it seeks information that is
not within Armstrongs possession, custody or control. Armstrong specifically objects to this
request to the extent that it seeks information protected by the attorney-client privilege, attorney
work product doctrine, or any other applicable privilege or immunity. Armstrong objects to this
request to the extent it is unreasonably cumulative or duplicative of other requests. Armstrong
further objects that the number of requests are abusive, unreasonable, and oppressive; that the
discovery sought is unreasonably cumulative and duplicative of admissions already within the
relators possession; and, that the admissions sought are not proportional to the needs of the case.
//
//
//
//
//
245
979791
Respectfully submitted,
KEKER & VAN NEST LLP
246
979791
CERTIFICATE OF SERVICE
I am employed in the City and County of San Francisco, State of California in the office of a
member of the bar of this court at whose direction the following service was made. I am over the
age of eighteen years and not a party to the within action. My business address is Keker & Van
Nest LLP, 633 Battery Street, San Francisco, CA 94111-1809.
On August 21, 2015, I served the following document(s):
LANCE ARMSTRONGS RESPONSES AND OBJECTIONS TO
RELATORS FIRST SET OF REQUESTS FOR ADMISSIONS
by E-MAIL VIA PDF FILE, by transmitting on this date via e-mail a true and
correct copy scanned into an electronic file in Adobe pdf format.
Robert E. Chandler
Tracy L. Hilmer
David M. Finkelstein
Robert Joseph McAuliffe
Gregory A. Mason
U.S. Department of Justice
Commercial Litigation Branch
Civil Division, Fraud Section
601 D Street, N.W., Room 9530
Washington, DC 20004
Darrell Valdez
Carl E. Ross
U.S. Attorneys Office
Judiciary Center Building
555 Fourth Street, NW
Washington, DC 20530
Darrell.Valdez@usdoj.gov
Carl.Ross@usdoj.gov
Robert.Chandler@usdoj.gov
Tracy.Hilmer@usdoj.gov
David.M.Finkelstein@usdoj.gov
Robert.McAuliffe@usdoj.gov
Gregory.A.Mason@usdoj.gov
Jackeline.M.Rosero@usdoj.gov;
Matthew.C.Golojuch@usdoj.gov
Robert Luskin
Paul Hastings LLP
875 15th Street, N.W.
Washington, DC 20006
Paul D. Scott
Lani Anne Remick
Law Offices of Paul D. Scott, P.C.
Pier 9, Suite 100
San Francisco, CA 94111
robertluskin@paulhastings.com
pdscott@lopds.com
laremick@lopds.com
247
979791
Marc S. Harris
Margaret Dayton
Scheper Kim & Harris LLP
One Bunker Hill
601 West Fifth Street, 12th Floor
Los Angeles, CA 90071
mharris@scheperkim.com
pdayton@scheperkim.com
(via Email)
Johan Bruyneel
c/o Mike Morgan
mike.morgan@morgansl.com
Executed on August 21, 2015, in San Francisco, California.
I declare under penalty of perjury under the laws of the United States of America that the above
is true and correct.
/s/ Alisa Thompson
Alisa Thompson
248
979791
Case
Case
1:10-cv-00976-CRC
3:12-cr-03481-BEN Document
Document429-3
14 Filed
Filed
03/08/13
09/21/15Page
Page
1 of
1 of
22
-
1
2
3
4
5
6
7
10
11
Plaintiff,
12
13
v.
FLOYD LANDIS,
14
Defendant.
15
16
17
Upon joint motion ofthe parties, the United States ofAmerica, by and through
18
its counsel, Laura E. DuffY, United States Attorney, and Phillip L. B. Halpern and
19
Peter 1. Mazza, Assistant U.S. Attorneys, and Defendant Floyd Landis, by and
20
21
through his counsel, Leo Cunningham, and good cause appearing therefor,
IT HEREBY IS ORDERED that Defendant pay restitution in the amount of
22
23
$478,354.54 pursuant to 18 U.S.C. 3663A, and in accordance with the terms and
conditions stated in the Deferred Prosecution Agreement (Doc. No.5), entered by
24
27
28
II
II
II
Case
Case
1:10-cv-00976-CRC
3:12-cr-03481-BEN Document
Document429-3
14 Filed
Filed
03/08/13
09/21/15Page
Page
2 of
2 of
22
United States may notify the Clerk ofCourt ofthe individual or entity's identity and
DA~~~
...
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28