2 collection of information to third parties (and if so, the identities of such individuals). Indeed, despite what Fusion would have this Court believe, its objections have n othing to do with the

scope

of the requests (which Plaintiffs’ counsel narrowed at Fusion’s request

, a fact

omitted from Fusion’s

Motion) or even concerns about use of the information outside the present

litigation (Plaintiffs’ counsel agreed to strict limitations on the use of any information provided –

including a “US attorney’s eyes onl y” provision)

, but rather its belief that it shou ld be shielded

entirely

from routine discovery requests, as demonstrated b y the fact that Fusion has produced

absolutely nothing in response to Plaintiffs’ subpoena.

1

Plaintiffs’ requests –

which consist of only eleven (11) document requests and ninet

een (19) targeted areas of inquiry for Fusion’s

deposition

–

are both reasonable and reasonably calculated to lead to the discovery of admissible

information. As such, Fusion’s Motion should be denied in its entir ety.

In further support of this Opposition, Plaintiffs state as follows. Factual Background In 2015

, Fusion GPS (“Fusion”) was retained by an unnamed client to perform opposition

research on the then Presidential candidate , Donald J. Trump. According to Fusion, it w as retained to research candi

date Trump’s “qualifications for public office and his ties to Ru ssia.”

See

Fusion GPS’ Motion to Quash Subp oena or, In the Alternative, For a Protective Order (hereinafter “Fusion’s Motion”), p. 1.

In turn, Fusion hired a private contractor, Christopher Steele (and his company Orbis Business Intelligence Limited), to collect information.

See

Exhibit 1

. Because Mr. Steele

1

Fusion’s insistence that it is exempt from the rules that govern the rest of us is not limited

solely to the present proceeding: Fusion has apparently responded to a congressional subpoena seeking documents concerning the dossier by producing little more than news clippings and thousands of pages of blank documents.

See

Exhibit 2

.