2020.08.20 - DOC104 - Zou (Linde) - Plaintiff's Objection To Defendant's Motion For Protective Order

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA
Bo Zou, §
§
Plaintiff §
§
vs. § NO. 4:19-CV-00554-JFH-JFJ
§
Linde Engineering North America, Inc. , §
§
Defendant.
§
§
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION

FOR PROTECTIVE ORDER
Pro Se Plaintiff Bo Zou files Plaintiff’s response in opposition to Defendant’s motion for
protective order. Defendant has been abusing protective orders in the discrimination case. Until
now, Defendant frivolously filed three (3) protective orders (Dkt. Nos. 20, 54, 94) without a
good cause, only based on Defendant’s lies to and blatantly misleading the Court.
(A). Defendant’s first protective order (Dkt. No. 20) filed on March 4, 2020, Defendant
asserted Plaintiff’s so-called threat to a third party and request a protective order. But, the
protective order granted by the Court was used to protect Defendant’s so-called secret
documents or files. Defendant falsified a lot of documents with the protective order. See
EXHIBIT “19”; and Dkt. Nos. 60, 86.
(B). Defendant’s second protective order (Dkt. No. 54) filed on June 18, 2020, Defendant
refused Defendant’s deposition with lies. Defendant lied and asserted Plaintiff did not notify
Defendant prior to June 5, 2020. See Dkt. No. 51, Pg. 3. However, Plaintiff has shown the Court
Plaintiff’s email to notify Defendant for deposition on June 2, 2020. See Dkt. No. 68, EXHIBIT
“2”. Plaintiff has given Defendant Twenty-one (21) days’ notice by e-mail, and Eighteen (18)
days’ notice by written notice. Plaintiff’s notice of deposition is in compliance with Fed. R. Civ.
P. 30 (a) and Local Rule LCvR30.1(a)(2). Defendant rejected Defendant’s deposition violating
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Fed. R. Civ. P. 30 and Local Rule LCvR30.1(a)(2). But, Defendant still sought protective order
with Defendant’s lies to and blatantly misleading the Court.
(C). Defendant filed Defendant’s third protective order (Dkt. No. 94) on August 11, 2020,
to request “Plaintiff to seek Leave of Court prior to making any further filings or serving
Defendant with any additional discovery requests or noticing any depositions, and further order
that Defendant is not required to respond to Plaintiff’s pending baseless motions.” But,
Defendant could not provide any rule, statute or authority to support Defendant’s protective
order. Defendant frivolously filed Defendant’s protective order to avoid sanctioning because
Plaintiff has filed Plaintiff’s motions to sanction on Defendant for Defendant’s perjury, falsified
documents, concealed document, contempt of the Court and other misconducts supported by
factual evidence in Plaintiff’s motions. See Dkt. Nos. 86, 89.
Also, Defendant filed a lot of frivolous and baseless motions to avoid producing documents,
sanctioning (including contempt of the Court), deposing, etc. See Dkt. Nos. 19, 20, 32, 44, 50, 51,
53, 54, 80, 94. Defendant seeks for this protective order to avoid sanctioning for Defendant’s
perjury, falsifying documents, refusing to produce documents, etc. See Dkt. Nos. 86, Pg. 3.
Moreover, Defendant seeks for this protective order to avoid sanctioning for Defendant’s
contempt of the Court. See Dkt. No. 89; Dkt. No. 100, Pg. 3, 4.
Further, Defendant did not confer with Plaintiff Defendant’s protective order and submitted
a certification in Defendant’s motion. Defendant’s protective order must be denied by the Court.
1. Defendant’s motion for protective order must be denied without a certification

Defendant did not confer with Plaintiff before Defendant filed the protective order.
Defendant could not provide a certification for the Court. Defendant violated Fed. R. Civ. P. 26
(c)(1) 1 and Local Rule LCvR37.1.2 Defendant’s motion for protective order must be denied.
____________________
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(1) In General. A party or any person from whom discovery is sought may move for a protective order in the
court where the action is pending—or as an alternative on matters relating to a deposition, in the court for the
district where the deposition will be taken. The motion must include a certification that the movant has in good
faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without
court action… (emphasis added).
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With respect to all motions or objections relating to discovery pursuant to Fed. R. Civ. P. 26 through 37 and
45, this Court shall refuse to hear any such motion or objection unless counsel for movant first advises the
Court in writing that counsel personally have met and conferred in good faith and, after a sincere attempt to
resolve differences, have been unable to reach an accord.
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2. Defendant seeks for protective order without a good cause
Defendant requested the Court that “Defendant moves the Court for a Protective Order
requiring Plaintiff to seek Leave of Court prior to making any further filings or serving
Defendant with any additional discovery requests or noticing any depositions, and further order
that Defendant is not required to respond to Plaintiff’s pending baseless motions.” See Dkt. No.
94, Pg. 1. However, there is NOT any rule, statue or authority to support Defendant’s requests to
limit or prohibit Plaintiff’s litigation right. Pursuant to Fed. R. Civ. P. 26(c)(1), a party may only
seek protective order with a good cause as follows:
(A) forbidding the disclosure or discovery;
(B) specifying terms, including time and place or the allocation of expenses, for the disclosure or
discovery;
(C) prescribing a discovery method other than the one selected by the party seeking discovery;
(D) forbidding inquiry into certain matters, or limiting the scope of disclosure or discovery to certain
matters;
(E) designating the persons who may be present while the discovery is conducted;
(F) requiring that a deposition be sealed and opened only on court order;
(G) requiring that a trade secret or other confidential research, development, or commercial information
not be revealed or be revealed only in a specified way; and
(H) requiring that the parties simultaneously file specified documents or information in sealed envelopes,
to be opened as the court directs.
Defendant’s requests for protective order are not in compliance with the protective orders
specified in Fed. R. Civ. P. 26(c)(1). Defendant seeks for protective order without a good
cause. Defendant’s requests for protective order must be denied by the Court.
3. Plaintiff’s requests for production of documents are in compliance with Federal
Rules of Civil Procedure 26, 34
A. Plaintiff must file motions to compel and for sanction because Defendant objected
to Plaintiff’s all requests for production of documents
Until now, Plaintiff filed five sets of requests for production of documents, total seventy-
nine (79) requests. However, Defendant always objected to Plaintiff’s requests and refused to
produce documents Plaintiff requested. This is why Plaintiff must file requests for production
of document, motions to compel and motions for sanctions. The Court never find that Defendant
answered a non-objection response to Plaintiff’s first, second, fourth and fifth sets of requests for
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production of documents. In Plaintiff’s third set of requests for production of documents,
Defendant not only objected to Plaintiff’s requests, but also cheated and misled the Court. See
Dkt. No. 60. Plaintiff lists Defendant’s responses to Plaintiff’s five sets of requests for
production of documents as follows:
(1). Defendant’s response to Plaintiff’s first request for production of documents (47
requests). See EXHIBIT “1”. Plaintiff’s all requests were objected and refused.
(2). Defendant’s response to Plaintiff’s second set of requests for production of documents
(10 requests). See EXHIBIT “2”. Plaintiff’s all requests were objected and refused.
(3). Defendant’s response to Plaintiff’s third set of requests for production of documents. (8
requests). See EXHIBIT “3”. Defendant’s not only refused to produce documents but also
cheated and misled the Court. See Dkt. No. 60, Pg. 2, 3, 4.
(4). Defendant’s response to Plaintiff’s fourth set of requests for production of documents (6
requests). See EXHIBIT “4”. Defendant’s refused to produce documents. See Dkt. No. 86, Pg. 2.
Defendant committed perjury, falsified documents, concealed documents, and lied to and misled
the Court. See Dkt. No. 86, Pg. 3, 4.
(5). Defendant’s response to Plaintiff’s fifth set of requests for production of documents (8
requests). See EXHIBIT “5”. Plaintiff’s all requests were objected and refused initially.
It’s very necessary for Plaintiff to file motions to compel and motions for sanctions.
Defendant asserted that Plaintiff filed so-called baseless motions (Dkt. No.’s 22, 24, 30, 31, 34,
38, 40, 41, 45, 59, 60, 67, 72, 76, 77, 85, and 86). See Dkt. No. 94, Pg. 2. Plaintiff lists
Plaintiff’s motions and shows the Court Plaintiff’s motions are necessary as follows:
(a). For Dkt. Nos. 22, 24, 30, 31, the Court ruled on Plaintiff’s motions to compel and for
sanctions for Plaintiff’s first and second sets of requests for production of documents. But,
Defendant still refuses to produce RFP Nos. 2, 3, 4, 6, 7, 21, and 26 requested in Plaintiff’s first
request for production of documents even if the Court ordered Defendant to produce the
documents. See Dkt. No. 37, Pg. 3, 5, 6.
(b). For Dkt. No. 38, the motion is pending for District Judge to rule. Plaintiff filed the
motion because magistrate judge’s rulings are clearly erroneous or contrary to law.
(c). For Dkt. No. 40, Plaintiff’s motion for change of Magistrate Judge, which is pending in
the Court. Plaintiff filed the motion because Magistrate Judge displayed a high favoritism to
Defendant, or antagonism to Plaintiff in the proceedings. Plaintiff’s motion is in compliance with
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28 U.S.C. §455(a).
(d). For Dkt. Nos. 40, 45, the Court ruled on Plaintiff’s motions for hearing.
(e). For Dkt. No. 59, the Court ruled on Plaintiff’s motion to Strike Defendant’s Response
and motion for sanction. Defendant filed Defendant’s Response to Plaintiff’s Motion to
Reconsider (Dkt. No. 49). But, Defendant did NOT serve on Plaintiff “Defendant’s Response to
Plaintiff’s motion to reconsider”. Defendant violated Fed. R. Civ. P. 5. It’s necessary for
Plaintiff to file Plaintiff’s motion to Strike Defendant’s Response and motion for sanction. But,
Defendant was never sanctioned by the Court for Defendant’s violation.
(f). For Dkt. No. 60, Plaintiff’s motion to compel and for sanctions for Plaintiff’s third set
request for production of documents, which is pending in the Court. Defendant refused to
produce documents, committed perjury, falsified documents, missed deadline of discovery, etc.
(g). For Dkt. No. 67, Plaintiff’s motion to object to the Court minute order (Dkt. No. 58) for
granting Defendant’s Opposed Motion to Stay Deposition. The motion is pending in the Court.
Plaintiff objected to the Court incorrect order, which was based on Defendant’s lies to refuse
Defendant’s deposition. Defendant violated Fed. R. Civ. P. 30(a) and Local rule LCvR30.1(a)(2).
Plaintiff’s motion is in compliance with Fed. R. Civ. P. 30(a) and Local rule LCvR30.1(a)(2).
(h). For Dkt. No. 72, Plaintiff’s motion for objecting to the Court order for joint status
report, which is pending in the Court. First, both parties filed a joint status report to the Court on
January 8, 2020. See Dkt. No. 16. Plaintiff has the right to object to file another joint status
report, which would help Defendant alter the terms both parties agreed in the joint status report.
Plaintiff’s motion is necessary and never baseless.
(i). For Dkt. Nos. 76, 77, Plaintiff’s motion for objecting to Magistrate Judge’s rulings (Dkt.
No. 70) issued on July 9, 2020, and motion to request the District Judge to rule pursuant to
Federal Rules of Civil Procedure. The motions are pending in the Court. Plaintiff’s motions are
necessary and never baseless because Magistrate Judge’s rulings are clearly erroneous or
contrary to law. Plaintiff’s motions are in compliance with Fed. R. Civ. P. 72(a).
(j). For Dkt. No. 85, Plaintiff’s motion for Objecting to the court order to refer Plaintiff’s
motion for change of magistrate judge to magistrate judge herself, which is pending in the Court.
The District Judge should have ruled on “Plaintiff’s motion for change of magistrate judge”
(Dkt. No. 40), but referred Plaintiff’s motion to Magistrate Judge herself. Plaintiff’s motion for
objecting is necessary and in compliance with 28 U.S.C. §455(a), and never baseless.
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(k). For Dkt. No. 86, Plaintiff’s Motion to Compel Production of Documents for Fourth Set
of Requests for Documents, and Motion for Sanctions, which are pending in the Court.
Defendant refused to provide documents Defendant should have provided. Also, Defendant
committed perjury, falsified documents, concealed documents and lied to and misled the Court.
Plaintiff’s motion is necessary and never baseless.
Defendant must show the Court which motion listed above Plaintiff should not file,
and which rule or which statute Plaintiff violated.
B. Defendant’s lies to and misleading the Court in Defendant’s motion for Protective
order
Defendant lied and asserted that “This is illustrated by Plaintiff’s most recent and baseless
motion for contempt, see Dkt. No. 89, in which Plaintiff blatantly attempts to mislead the Court
(and blatantly attempted to mislead Defendant) with respect to the Court’s order on his motion
to compel.” See Dkt. No. 94, Pg. 2.
But, Defendant’s lies cannot cover factual evidence. Plaintiff has provided detailed factual
evidence for Defendant’s contempt of the Court in “Plaintiff’s motion for contempt” (Dkt. Nos.
89, 100). Plaintiff shows the Court Plaintiff’s grounds and factual evidence as follows:
First of all, in Plaintiff’s original RFP Nos. 2, 3, 4, 7, Plaintiff clearly stated that what
documents Plaintiff requested on January 13, 2020 (EXHIBIT “1”, Pg. 6, 7, 8), including what
type of documents, who made, which project, when, etc. as follows:
(a). RFP. 2: Provide all piping specifications made by Plaintiff in PDF format for Stock
Plant project on February 21, 2019, and piping class specifications made by Plaintiff for Husky
1 & 2 projects on April 30, 2019. (emphasis added)
(b). RFP. 3: Provide all piping class specifications for XTO project in PDF format, which
includes the versions prior to and after February 21, 2019. (emphasis added)
(c). RFP. 4: Provide Linde technical piping specifications in PDF format, which includes
the version prior to February 21, 2019 and the current version. (emphasis added)
(d). RFP. 7: Provide all piping class specifications made by Plaintiff in PDF format for
Defendant’s LR6400 project on August 6, 2019. (emphasis added)
On March 3, 2020, Plaintiff in good faith narrowed the requests for piping class
specifications to C40 and C60 only. See EXHIBIT “6”.
Further, Plaintiff clearly showed the Court that “Plaintiff states that Plaintiff has narrowed
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the requests to Cryogenic piping class specifications C40 and C60 on March 2 & 3, 2020. But,
Defendant still rejected Plaintiff’s request.” in Plaintiff’s motion to compel documents for
Plaintiff’s first request for production of documents. See Dkt. No. 22, Pg. 4. Also, the Court
ordered Defendant to produce these documents following Plaintiff’s requests.
“RFP 2, 3, 4, 7, 36: Granted, as limited by Plaintiff. Plaintiff limited

requests 2, 3, 4, and 7 to “cryogenic piping class specifications C40 and
C60 on March 2 & 3, 2020.” ECF No. 22 at 4. ………” See Dkt. No. 37, Pg. 3.
After Plaintiff narrowed all piping class specifications to C40 and C60, and granted by the
Court. Plaintiff’s requests for RFP Nos. 2, 3, 4, 7 should be as follows:
(a). RFP. 2: Provide C40 and C60 piping class specifications made by Plaintiff in PDF
format for Stock plant project on February 21, 2019, and piping class specifications made by
Plaintiff for Husky 1 & 2 projects on April 30, 2019.
(b). RFP. 3: Provide C40 and C60 piping class specifications for XTO project in PDF
format, which includes the versions prior to and after February 21, 2019.
(c). RFP. 4: Provide Linde technical piping specifications C40 and C60 in PDF format,
which includes the version prior to February 21, 2019 and the current version.
(d). RFP. 7: Provide C40 and C60 piping class specifications made by Plaintiff in PDF
format for Defendant’s LR6400 project on August 6, 2019.
The due date of producing documents ordered by Court’s second order (Dkt. No. 70) is
July 14, 2020. Defendant deliberately produced harassed piping class specifications made by
Kenny Sharp, NOT by Plaintiff on July 9, 2020. See EXHIBIT “7”. Three weeks later, on July
30, 2020, Plaintiff found that Defendant never produced the documents ordered by the Court. So,
Plaintiff in good faith requested Defendant to produce the documents following Plaintiff’s
requests and the Court’s order on July 30, August 4 and 5, 2020. See EXHIBIT “8”. Defendant
must show the Court how could Plaintiff misrepresent the Court’s order after Defendant
had deliberately produced wrong and harassed piping class specification made by Kenny
Sharp and refused to produce other documents? Plaintiff never contacted Defendant to
request “all versions” piping class specification before Defendant deliberately produced piping
class specification made by Kenny Sharp. In Plaintiff’s email sent to Defendant on July 30, 2020,
Plaintiff only used the “original” requests, but made “Plaintiff” with bold mark to remind
Defendant of producing piping class specification made by Plaintiff, NOT by Kenny Sharp.
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See EXHIBIT “7”. For example:
Finally, on August 5, 2020, Plaintiff clearly reminded Defendant of producing what piping class
specification and who made. See EXHIBIT “8”. Plaintiff shows the Court for RFP’s 2 as below:
But, Defendant did not give Plaintiff any response and refused to produce any documents to
follow the Court order. On the contrary, Defendant alleged Plaintiff mispresent the Court order.
Defendant obviously and blatantly misleads the Court.
Moreover, Defendant asserted that Defendant produced all the documents “As to the other
purported items in Plaintiff’s motion for contempt, Defendant expressly informed Plaintiff that it
produced all documents in possession, and that there were no other responsive documents.” See
Dkt. No. 94, Pg. 3 (emphasis added). The Court should order Defendant to appear before this
Court to show what documents Defendant produced. Defendant deliberately produced a lot of
harassed piping class specifications made by Kenny Sharp, NOT by Plaintiff on July 9, 2020.
See EXHIBIT “7”. The Court can see the documents (catalog) produced by Defendant are never
the documents Plaintiff requested and ordered by the Court. Defendant never produced any C40
or C60 piping class specifications made by Plaintiff and ordered by the Court even if plaintiff
requested Defendant to produce these documents over and over. See EXHIBIT “8”.
Further, Defendant asserted “Defendant expressly informed Plaintiff that it produced all
documents in possession, and that there were no other responsive documents.” i.e. Defendant
does not possess these documents. Plaintiff shows the Court the evidence that these documents
exist, and are possessed by Defendant as follows:
For RFP. No. 2, the evidence for Plaintiff to make piping class specification for Stock plant
project on February 21, 2019. See EXHIBIT “9”.
The evidence for Plaintiff to make piping class specification for Husky 1 & 2 projects on
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April 30, 2019. See EXHIBIT “10”.
For RFP. No. 3, C40 and C60 piping class specifications for XTO project exist and
possessed by Defendant. See EXHIBIT “9”.
For RFP. No. 4, technical piping specifications C40 and C60, which includes the version
prior to February 21, 2019 and the current version, exist and possessed by Defendant. See
EXHIBIT “9”.
For RFP. No. 7, C40 and C60 piping class specifications for Defendant’s LR6400 project
on August 6, 2019 exist and possessed by Defendant. See EXHIBIT “11”. Defendant blatantly
lied to and misled the Court again. Defendant is in contempt of the Court without any questions.
For RFP. No. 6, piping engineer job’s sheets for Defendant’s LR6400 project when
Plaintiff started to assign jobs to younger piping design engineers, Mr. Kenny Sharp and Mr.
Dustin Duncan, exist and possessed by Defendant. See EXHIBIT “12”.
For RFP. No. 21, Defendant’s contribution on Plaintiff’s insurance exists, and is possessed
by Defendant. Plaintiff only knows Plaintiff’s contribution. See EXHIBIT “13”.
For RFP. No. 26, the documents exist, and are possessed by Defendant. Defendant admitted
Kenny Sharp made a big mistake, but covered Kenny Sharp’s mistake. See EXHIBIT “14”. Also,
when Plaintiff complained Kenny Sharp on May 10, 2010, Plaintiff clearly stated that Defendant
wasted a lot of money to solve the problem made by Kenny Sharp. See EXHIBIT “15”.
C. Plaintiff’s Factual evidence to disclose Defendant’s obvious and blatantly
misleading the Court on Plaintiff’s requests for production of Documents
Plaintiff only requested Eleven (11) sets written discovery until now, including:
(1). Five sets of requests for production of documents, total seventy-nine (79) requests;
(2). Three sets of interrogatories, total twenty-three (23) interrogatories;
(3). Three sets of admissions, total twenty-three (23) admissions.
Both interrogatories and admissions Plaintiff requested are less than the numbers of requests
of twenty-five (25) specified by Fed. R. Civ. P. 33(a)(1) and Local Rule LCvR36.1, respectively.
For Plaintiff’s total seventy-nine (79) requests for production of documents, there are fifty-seven
(57) requests in Plaintiff’s first and second sets of requests for production of documents. There
are only about average seven (7) requests/set for Plaintiff’s third, fourth and fifth sets of requests
for production of documents. Defendant must show the Court how Plaintiff harasses
Defendant with only seven (7) requests/set for production of documents.
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Moreover, Defendant always objected and refused to produce documents. See
EXHIBIT “1”—“5”. Defendant even refused to produce documents RFP. 2, 3, 4, 6, 7, 21, 26
even if these documents are ordered to produce by the Court on May 19, 2020. See Dkt. No. 37.
Further, Plaintiff could not even get Plaintiff’s emails communicated with Plaintiff’s
supervisor Jerry Gump, young engineers Kenny Sharp and Dustin Duncan, and other key
witnesses. Defendant does its best to prevent Plaintiff from getting evidence by concealing
documents, committing perjury, falsifying documents, etc.
For Plaintiff’s first and second sets of requests for production of documents, Defendant
objected to all the requests. See EXHIBIT “1”, “2”. Defendant must show the Court how
Defendant was oppressed or harassed, and how big tremendous burdens was posed on
Defendant by Plaintiff’s requests. Moreover, the Court never alleged that Plaintiff’s requests
are burdensome or harassed after ruling. See Dkt. No. 37. Defendant’s assertions all are lies and
pretext. For example, for Plaintiff’s second set of requests for production of documents RFP 3, 6,
7, Defendant asserted that “Plaintiff later explained in one his motions to compel that he needed
these documents to show how his former attorneys attempted to “cheat” him. The Court denied
Plaintiff’s motion to compel these documents.” See Dkt. No. 94, Pg. 4 (emphasis added). For
RFP 6, 7, Defendant had repeatedly asserted with the same pretext as that in Defendant’s
Response in Opposition to Plaintiff’s Motion to Compel Production of Documents for Plaintiff’s
Second Request for Documents. See Dkt. No. 35, Pg. 3, 4. For RFP 3, Defendant never asserted
before. See Dkt. No. 35, Pg. 2. In order to demonstrate Defendant counsels blatantly mislead the
Court, Plaintiff lists RFP 3, 6, 7, and answers Defendant’s assertions as follows:
(a). REQUEST FOR PRODUCTION NO. 3: Provide any documents, emails, text messages, records of
phone calls received via any third parties, but not limited to person, companies, recruiters, or government
agency, who contact my former employers, my former clients, and my former colleagues, IRS, Social Security
Administration, any Federal and Local Court regarding Plaintiffs employment information, tax, Social Security
earning, and any lawsuit information since October 18, 2019.
The request is never relevant to Defendant’s assertion for Plaintiff to allege former attorneys
so-called “cheating”. Plaintiff has the right to request the documents because Defendant contacted
Plaintiff’s former employers without Plaintiff’s permission. See Dkt. No. 34. The Court can see
Plaintiff’s request never harasses Defendant. Defendant had objected to Plaintiff’s request and
refused to produce any documents. See EXHIBIT “2”, Pg. 8.
Defendant must show the Court how Plaintiff harassed Defendant? How tremendous
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burdens Plaintiff posed on Defendant? Where is Defendant asserted “cheating” by
Plaintiff’s former attorneys?
(b). REQUEST FOR PRODUCTION NO. 6: Provide any documents, emails, mails, text messages,
records of phone calls received from and replied to Attorney Loren Gibson in September, 2019, and since
October, 2019.
Attorney Loren Gibson was ever interested in the discrimination case. Loren Gibson sent an
investigation letter to Defendant in September, 2019. Since then, Loren Gibson never contacted
Plaintiff any more even if Plaintiff called him and left a message, or sent him a few emails. The
documents Plaintiff requested involved in the investigation letter for the case. The most important
documents requested by Plaintiff are Defendant’s replies to the investigation letter. These documents
are relevant to the case. The Court can see Plaintiff’s request is reasonable and relevant to the case.
(c). REQUEST FOR PRODUCTION NO. 7: Provide any documents, emails, mails, text messages,
discussion, records of phone calls received from and replied to Attorney Johnnie J. James III since October 25,
2019.
Attorney Johnnie J. James III signed a representing agreement with Plaintiff on October 25,
2019. Johnnie J. James III called Defendant counsel Rector G. Jonathan to see whether the case may
be solved at outside of this Court around October 28, 2019. On November 1, 2019, Johnnie J. James
III told Plaintiff Defendant’s counsel Rector G. Jonathan told him that settlement needs ninety (90)
days to be finished. Although Plaintiff filed complaint to the Court on October 18, 2019, Plaintiff did
not serve the pleadings on Defendant, yet. After ninety (90) days, the case would be dismissed
automatically. So, Plaintiff alleged both Defendant’s counsel Rector G. Jonathan and Attorney
Johnnie J. James III cheating, not only Johnnie J. James III’s cheating. See Dkt. No. 30, Pg. 7. Also,
Johnnie J. James III asked for Plaintiff around in one week to go to his office to review some
documents, which would be provided by Defendant. Plaintiff’s request for the documents is
reasonable and in compliance with Fed. R. Civ. P. 26, 34. The Court has ruled and never alleged
that Plaintiff’s requests are burdensome or harassed Defendant. Defendant misled the Court.
For Plaintiff’s third set of requests for production of documents, Defendant’s not only
refused to produce documents but also cheated and misled the Court. See Dkt. No. 60, Pg. 2, 3, 4.
Defendant asserted that “Plaintiff sought correspondence between Defendant and third parties
regarding “Plaintiff’s apartment matter” and “Plaintiff’s complaint of car damage.” See Dkt.
No. 94, Pg. 4. Plaintiff lists RFP Nos. 6, 7, 8 and answers Defendant’s assertions as follows:
(a). REQUEST FOR PRODUCTION NO. 6: Provide emails between Ms. Genie Churchill and Ms.
Cheryl Roberts of the third party National Corporate Housing-Tulsa, on October 15, 2018, involving in
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Plaintiff’s apartment matter. (E-mails must be screenshot and attached a copy of content).
Plaintiff requested the emails involving in Plaintiff’s apartment matter because Defendant
provided some emails between Genie Churchill and Cheryl Roberts to allege Plaintiff. See
EXHIBIT “16”. Plaintiff’s request for emails between Genie Churchill and Cheryl Roberts are
reasonable and relevant to the discrimination case.
(b). REQUEST FOR PRODUCTION NO. 7: Provide emails between Ms. Amie Schlosberg of
Defendant and Ms. Stephanie Canada of the third party GEMINI ROSEMONT, on June 11, 2019, involving in
Plaintiff’s complaints and car damage. (E-mails must be screenshot and attached a copy of content).
(c). REQUEST FOR PRODUCTION NO. 8: Provide emails between Ms. Amie Schlosberg and Ms.
Deana Hoey on June 11, 2019, involving in Plaintiff’s complaints and car damage. (E-mails must be
screenshot and attached a copy of content).
Defendant objected to Plaintiff’s requests for RFP Nos. 7, 8 in Defendant’s response. Also,
Defendant never produced any documents. See EXHIBIT “3”, Pg. 7, 8. Plaintiff requested the
emails involving in Plaintiff’s complaints and car damage because Defendant provided some
emails between Amie Schlosberg and Stephanie Canada, and between Amie Schlosberg and
Deana Hoey to allege Plaintiff. See EXHIBIT “17”. Plaintiff’s request for emails between Amie
Schlosberg and Stephanie Canada, and between Amie Schlosberg and Deana Hoey are
reasonable and relevant to the discrimination case. Defendant must show the Court how
Plaintiff harassed Defendant? How tremendous burdens Plaintiff posed on Defendant?
For Plaintiff’s fourth set of requests for production of documents, Defendant objected to
all the requests. See EXHIBIT “4”. Defendant asserted that “In Plaintiff’s fourth set of requests
for production, he continued to seek correspondence between Defendant and third-party ICC
Group—correspondence which this Court already held was irrelevant to his lawsuit.” See Dkt.
No. 94, Pg. 4. Defendant misled the Court again. Plaintiff lists RFP 5 as follows:
REQUEST FOR PRODUCTION NO. 5: Provide documents or communications between
Defendant and ICC Group Inc. (ICC) except the email ICC contacted the Defendant on February 24, 2020.
Defendant’s objected to Plaintiff’s request and refused to produce any documents. See
EXHIBIT “4”, Pg. 7. However, the Court never prohibited Plaintiff from getting any documents
from Defendant involving any third parties, including ICC Group Inc. (“ICC”). The Court order
only denied Plaintiff’s subpoena to ICC to request Plaintiff’s employment documents and any
documents with other third parties. See Dkt. No. 37, Pg. 10.
Defendant got Plaintiff’s email from ICC with improper means without Plaintiff’s
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permission, and willfully used Plaintiff’s email to allege Plaintiff threated ICC and Defendant’s
safety. See EXHIBIT “18”. So, Plaintiff needs to request Defendant to produce any other emails
or documents got from ICC for the case, except Plaintiff’s email submitted to the Court by
Defendant. Plaintiff’s request is in compliance with Fed. R. Civ. P. 26, 34. Defendant must
show the Court why Plaintiff could not request Defendant to produce other emails or
documents got from ICC?
For Plaintiff’s Fifth set of requests for production of documents, including supplemental
request, Plaintiff lists Plaintiff’s requests as follows:
PLAINTIFF’S FIFTH SET OF REQUESTS FOR
PRODUCTION OF DOCUMENTS
1. Provide e-mails between Plaintiff and Plaintiff’s supervisor Jerry Gump
from April 28, 2019 to August 7, 2019.
2. Provide e-mails between Plaintiff and young engineer Kenny Sharp

from April 28, 2019 to August 7, 2019.
3. Provide e-mails between Plaintiff and young engineer Dustin Duncan

from June 1, 2019 to July 1, 2019.
4. Provide e-mails between Plaintiff and Terry Albrecht from June 1, 2019 to
July 26, 2019.
5. Provide e-mails between Plaintiff and Kelly Leitch, from

March 1, 2019 to June 20, 2019.
6. Provide internal investigation reports made by Deana Hoey for Plaintiff’s

complaints on May 6 & 12, 2020.
7. Provide PRIV 0001, 0002 listed on Defendant’s Privilege Log. These organization
charts made on September 5, 2019 are never work product privilege.
PLAINTIFF’S FIFTH SET OF REQUESTS FOR
PRODUCTION OF DOCUMENTS--SUPPLEMENTAL
1. Please provide all documents obtained/received by way of subpoena or deposition on
written questions, relating to this Lawsuit, Plaintiff, or the factual or legal claims in the
Complaint.
Defendant objected to all the requests and refused to produce any documents initially. See
EXHIBIT “5”. After Plaintiff in good faith to request Defendant to produce documents over and
over, Plaintiff finally produced RFP No. 7 documents PRIV 0001, 0002. See EXHIBIT “19”. But,
13
some documents in PRIV 0001, 0002 are falsified by Defendant. Defendant had stated that both
Kenny Sharp and Dustin Duncan are piping design engineers only, NOT piping engineers. See Dkt.
No. 86, EXHIBIT “3”, Pg. 4. But, the document of “Linde [Zou] 002830” shows that both Kenny
Sharp and Dustin Duncan are piping engineers. Defendant continued falsifying documents. This is
why Defendant does its best to prevent Plaintiff from filing further motions.
After Plaintiff requested Defendant to produce documents over and over, Defendant answered
Plaintiff’s supplemental request as“Regardless, we have no documents responsive to this request, but
will supplement should we receive any.” See EXHIBIT “20”.
For RFP 6, Plaintiff requested Defendant to produce Defendant’s internal investigation report
for Plaintiff’s complaint. Deana Hoey mentioned she investigated some people except Jerry Gump,
such as Adam Milad’s supervisor Jehna Ferster, etc. The internal investigation report is very strongly
relevant to the case. However, Defendant refused to produce the report. Defendant must show the
Court how Plaintiff harassed Defendant or posed tremendous burdens on Defendant.
The emails between Plaintiff and other five (5) colleagues are direct evidence for the
discrimination case. The emails, between Plaintiff and Jerry Gump, Kenny Sharp, and Dustin Duncan,
can show Plaintiff was treated differently from young engineers or discriminated by Defendant. The
the emails, between Plaintiff and Terry Albrecht, Kelly Leitch, can demonstrate Plaintiff’s excellent
work and Plaintiff have the capability as an equipment engineer for job reassignment. But, Defendant
refused to produce these documents. Defendant must show the Court how Plaintiff harassed
Defendant or posed tremendous burdens on Defendant.
Defendant’s pretext for Plaintiff’s requests for these emails is that “Plaintiff’s most recent set
of discovery requests seeks months’ worth of e-mails—without any subject matter or other
limitation whatsoever—between Plaintiff and six other custodians. See Exhibit 5, Plaintiff’s Fifth
Set of Requests for Production. But this Court has already ruled on Plaintiff’s overly broad
email requests and ordered Plaintiff to provide the names of only two custodians for Defendant
to conduct searches, see Dkt. No. 37 at pp. 4-5, which Defendant has already provided.” See Dkt.
No. 94, Pg. 4 (emphasis added). However, the Court ordered Plaintiff to provide the names of
only two custodians for Defendant to conduct searches for RFP 15—19 in Plaintiff’s first
request for Production of Documents. The Court order states that “As a reasonable limit on
Requests 15-19, which are vague and would require extensive ESI searches, the Court orders
Plaintiff to provide the names of two custodians, or individuals within the company, whose email
accounts are most likely to contain relevant information.” See Dkt. No. 37,Pg. 4 (emphasis
14
added). Plaintiff lists RFP Nos.15—19 as follows:
15. Provide working e-mails, discussions, conversations, Telephone conversations, correspondences or
memos among defendant’s top management, engineering manager and HR supervisor, HR employee,
i.e. among President Carlos Conerly, Vice President Becky Ford, Vice President David Close, Mr.
Jerry Gump, Mr. Aaron Watson and Ms. Deana Hoey dated from 05/06/2019 to 10/31/2019, in which
George, George Zou, Bo, Zou or Bo Zou is mentioned.
16. Provide working e-mails, correspondences or memos among defendant’s former head of operation
Mr. Art Thompson, engineering manager Mr. Gerald (Jerry) Gump, and piping group leader Mr. Eli
McDaniel dated from 08/10/2018 to 10/31/2019, in which George, George Zou, Bo, Zou or Bo Zou
is mentioned.
17. Provide working e-mails among engineering manager Mr. Gerald (Jerry) Gump, Mr. Eli
McDaniel, Mr. Kenny Sharp, Mr. Dustin Duncan and Ms. Nancy Hubbard dated from 9/10/2018 to
10/31/2019, in which George, George Zou, Bo, Zou or Bo Zou is mentioned.
18. Provide working e-mails among engineering manager Mr. Gerald (Jerry) Gump, Mr. Adam Milad,
Mr. Kyle Hennessey, Mr. Charlie Davis, Mr. Amol Sawant and Bob Wang dated from 09/20/2018 to
10/31/2019, in which George, George Zou, Bo, Zou or Bo Zou is mentioned.
19. Provide working e-mails among engineering manager Mr. Gerald (Jerry) Gump, Mr. Arthur Denzau,
and Mr. Vaibhav Patel dated from 10/01/2018 to 10/31/2019, in which George, Bo, Zou, George Zou
or Bo Zou is mentioned.
The Court can see that RFP Nos. 15—19 ordered by the Court are entirely different from RFP
Nos. 1—5 in Plaintiff’s fifth set of requests for production of documents. Defendant misled the
Court again. Plaintiff’s requests for production of documents are reasonable and in compliance with
Fed. R. Civ. P. 26, 34, and Local Rules. Further, Plaintiff requested Defendant to produce documents
for Plaintiff’s fifth set of requests for production of documents on June 22 & 23, 2020. But,
Defendant never objected to Plaintiff’s requests before. Defendant’s allegation for Plaintiff’s
discovery is frivolous and baseless.
4. Conclusion
WHEREFORE, Defendant’s motion for protective order must be denied because the motion
for protective order is frivolous and baseless, and without a certification. Defendant never
produced the documents ordered by the Court by the due date of July 14, 2020. Defendant is in
contempt of the Court. Defendant willfully and deliberately concealed documents, and misled the
Court. Plaintiff’s requests for production of documents are in compliance with Fed. R. Civ. P. 26,
34, and Local Rules. Defendant filed the motion to avoid sanctioning. Plaintiff respectfully
requests the Court enter an order denying Defendant’s motion for protective order.
15
Dated: August 20, 2020
Respectfully Submitted,
Bo Zou
7972 S Sheridan Road, Apt. 314
Tulsa, OK 74133
Phone: 713-835-8655
Pro Se Plaintiff
16
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of a duplicate of the above and foregoing
Plaintiff’s Response in opposition to Defendant’s motion for protective order has been served
upon the opposing party, or his attorney of record, to the following e-mail address on the 20th
day of August, 2020.
[email protected]
[email protected]
[email protected]
[email protected]
Bo Zou
Pro Se Plaintiff
17
EXHIBIT “1”
EXHIBIT “2”
Bo Zou, §
§
Plaintiff §
§
vs. § NO. 4:19-CV-00554-JED-JFJ
§
Linde Engineering North America, Inc., §
§
Defendant. §
DEFENDANT’S OBJECTIONS AND RESPONSES

TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION
TO: Pro Se Plaintiff¸ Bo Zou, 7972 S Sheridan Road, Apt. 314, Tulsa, OK 74133
Pursuant to Federal Rule of Civil Procedure 34, Defendant Linde Engineering North
America, Inc. (“LENA” or “Defendant”) serves the following Objections and Responses to
Plaintiff’s Second Request for Production.
DEFENDANT'S OBJECTIONS AND RESPONSES TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION – PAGE 1
Dated: March 26, 2020 Respectfully submitted,
/s/ Jessica L. Craft

Jonathan G. Rector
OBA No. 30691
LITTLER MENDELSON, P.C.

A Professional Corporation
2001 Ross Avenue
Suite 1500, Lock Box 116
Dallas, TX 75201
214.880.8100
214.880.0181 (Fax)
And
Jessica L. Craft
OBA No. 31126

1301 McKinney Street, Suite 1900
Houston, TX 77010
713.951.9400
713.951.9212 (Fax)
ATTORNEYS FOR DEFENDANT LINDE

ENGINEERING NORTH AMERICA, INC.
This is to certify that on March 26, 2020 the undersigned mailed a copy of this filing
via Electronic Mail, to the following:
BO ZOU
7972 SOUTH SHERIDAN ROAD, APT. 314
TULSA, OKLAHOMA 74133
Pro Se Plaintiff
SENT VIA EMAIL: [email protected]; [email protected];

[email protected]

Jessica L. Craft
TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Provide any correspondence, documents, emails,

text messages, records of phone calls between Defendant and any third parties, but not limited to
person, companies, job recruiters, or government agency, about the lawsuit since October 18,
2019.
RESPONSE: Defendant objects to RFP No. 2 because it seeks information and/or documents
protected from disclosure by the attorney-client privilege, the work product doctrine, and/or
other privileges and immunities. Defendant further objects to this RFP as overly broad and
unduly burdensome. As worded, this RFP would require Defendant to search the emails, text
messages and phone records of all Defendant’s “agents, employees, attorneys, and other persons
acting for or on behalf of Defendant” to determine whether any of those individuals may have
mentioned or discussed the factual or “legal” allegations in Plaintiff’s Complaint with any “third
parties, but not limited to person, companies, job recruiters, or government agency.” The burden
associated with searching, collecting, and reviewing such documents is therefore not
proportional to the needs of this case. Finally, Defendant further objects to this RFP as an
attempt to solicit information to further Plaintiff’s harassment of third-parties who may possess
information related to Plaintiff’s employment history.
Defendant states that it has not communicated with any job recruiters, companies, or government
agencies about Plaintiff’s employment with Defendant other than ICC Group after Plaintiff’s
service of a subpoena duces tecum on that company. Defendant is withholding documents
pursuant to its objections.
REQUEST FOR PRODUCTION NO. 2: Provide any documents, emails, text messages,
records of phone calls received from any third parties, but not limited to person, companies, or
government agency, about Plaintiffs personal information, employment information, tax return
information, security earning information, etc. since October 18, 2019
mentioned or discussed Plaintiff’s employment, financial information, tax return information,
social security information or “etc.” with any “third parties, but not limited to person, companies,
or government agency.” The burden associated with searching, collecting, and reviewing such
documents is therefore not proportional to the needs of this case. Finally, Defendant further
objects to this RFP as an attempt to solicit information to further Plaintiff’s harassment of third-
parties who may possess information related to Plaintiff’s employment history.
Defendant states that it has not received any documents from third parties related to Plaintiff’s
lawsuit. Defendant is withholding documents pursuant to its objections.
records of phone calls received via any third parties, but not limited to person, companies,
recruiters, or government agency, who contact my former employers, my former clients, and my
former colleagues, IRS, Social Security Administration, any Federal and Local Court regarding
Plaintiffs employment information, tax, Social Security earning, and any lawsuit information
since October 18, 2019.
mentioned or discussed Plaintiff’s employment with any “third parties, but not limited to person,
companies, or government agency.” The burden associated with searching, collecting, and
reviewing such documents is therefore not proportional to the needs of this case. Defendant
further objects to this RFP as an attempt to solicit information to further Plaintiff’s harassment of
third-parties who may possess information related to Plaintiff’s employment history. Finally,
Defendant objects to this RFP because, as phrased, it seeks documents unknown and/or not
within the possession, custody or control of the Defendant to the extent it seeks documents
showing communication between third parties outside of the control of Defendant (e.g.¸
correspondence between Plaintiff’s “former employers,” “former clients,” “former colleagues,”
and various government agencies and state and federal courts). Defendant is withholding
documents pursuant to its objections.
records of phone calls received via all agents, representatives, or employees of LENA who
contact my former employers, my former clients, my former colleagues, IRS, Social Security
Administration, any Federal and Local Court regarding Plaintiffs employment information, tax,
Social Security earning, and any lawsuit information since October 18, 2019.
mentioned or discussed Plaintiff’s employment with any “third parties, but not limited to person,
companies, or government agency.” The burden associated with searching, collecting, and
reviewing such documents is therefore not proportional to the needs of this case. Defendant
further objects to this RFP as an attempt to solicit information to further Plaintiff’s harassment of
third-parties who may possess information related to Plaintiff’s employment history. Finally,
Defendant objects to this RFP because, as phrased, it seeks documents unknown and/or not
within the possession, custody or control of the Defendant to the extent it seeks documents
showing communication between third parties outside of the control of Defendant (e.g.¸
correspondence between Plaintiff’s “former employers,” “former clients,” “former colleagues,”
and various government agencies and state and federal courts). Defendant is withholding
documents pursuant to its objections.
REQUEST FOR PRODUCTION NO. 5: Provide all documents and evidence to support
Defendant's non-discrimination and defense.
RESPONSE: Defendant objects to this request as it is facially overbroad, premature, and unduly
burdensome. See, e.g., Cotracom Commodity Trading Co. v. Seaboard Corp., 189 F.R.D. 655, 665 (D.
Kan. 1999) (holding that “omnibus” phrases rendered discovery request facially overbroad and unduly
burdensome); Mackey v. IBP, Inc., 167 F.R.D. 186, 197-98 & 205-06 (D. Kan. 1996) (“Such phrases
often require the answering party to engage in mental gymnastics to determine what information may or
may not be remotely responsive.”); Robbins v. Camden City Bd. of Education, 105 F.R.D. 49, 60 (D.N.J.
1985) (discussing that “a literal reading” of a request for all documents that “refer to or relate to” plaintiff
“would require the defendant to provide a copy of every document in its possession, since all of these
documents could conceivably ‘refer or relate’ to plaintiff's employment.”); Milburn v. Life Investors Ins.
Co. of Am., No. CIV-04-0459-C, 2005 U.S. Dist. LEXIS 47362, at *5 (W.D. Okla. Jan. 19, 2005)
(rejecting use of “the omnibus term ‘reflecting’ in conjunction with a general category of documents . . .
fails to meet the particularity requirement of Rule 34”); American Friends Serv. Cmte. v. City & County
of Denver, No. 02-N-740 (CBS), 2004 U.S. Dist. LEXIS 18474, at *14 (D. Colo. Feb. 19, 2004)
(discussing that a “global” discovery request that seeks all documents relating to a particular event is
objectionable).This request seeks documents protected by attorney-client privilege and the work
product doctrine. It effectively seeks Defense counsel’s entire file. Defendant further objects that
the request is vague and confusing in its use of the phrase “all documents and evidence” as it
does not identify the documents with reasonable particularity as required by Rule 34(b)(1)(A).
Defendant refers Plaintiff to the documents previously produced and reserves the right to
supplement, as necessary. Defendant is not withholding documents pursuant to its objections.
REQUEST FOR PRODUCTION NO. 6: Provide any documents, emails, mails, text messages,
records of phone calls received from and replied to Attorney Loren Gibson in September, 2019,
and since October, 2019.
RESPONSE: This request is overly broad, irrelevant, and not reasonably calculated to lead to
admissible evidence. Defendant objects to this request because it seeks information in Plaintiff’s
possession or equally available to Plaintiff. For example, Plaintiff is the best source of
information regarding his former attorneys in this case. Plaintiff is also the best source of
information regarding his former attorney’s communications, if any. Defendant further objects to
this RFP as an attempt to solicit information to further Plaintiff’s harassment of third-parties.
discussion, records of phone calls received from and replied to Attorney Johnnie J. James III
since October 25, 2019
discussion, records of phone calls received from and replied to any other Attorneys, excluding
Littler Attorneys, Mr. Loren Gibson and Mr. Johnnie J. James III, since September 3, 2019.
records of phone calls received from any job recruiters about any job position discussion with
Plaintiff.
RESPONSE: This request is irrelevant, overly broad, vague, ambiguous, and not reasonably
calculated to lead to admissible evidence. Whether job recruiters contacted Defendant following
Plaintiff’s separation from employment is not materially relevant to the claims or defenses in this
action. Defendant further objects to this RFP as an attempt to solicit information to further
Plaintiff’s harassment of third-parties.
records of phone calls received from any job recruiters about any job position discussion with
Plaintiff.
RESPONSE: This request is irrelevant, overly broad, vague, ambiguous, and not reasonably
calculated to lead to admissible evidence. Whether job recruiters contacted Defendant following
Plaintiff’s separation from employment is not materially relevant to the claims or defenses in this
action. Defendant further objects to this RFP as an attempt to solicit information to further
Plaintiff’s harassment of third-parties.
4831-6777-6695.2 104712.1001
EXHIBIT “3”
Bo Zou, §
§
Plaintiff §
§
vs. § NO. 4:19-CV-00554-JED-JFJ
§
§
Defendant. §

TO PLAINTIFF’S THIRD REQUEST FOR PRODUCTION
Plaintiff’s Third Request for Production.

Dated: May 6, 2020 Respectfully submitted,

Jonathan G. Rector
OBA No. 30691

2001 Ross Avenue
Dallas, TX 75201
214.880.8100
214.880.0181 (Fax)
And
Jessica L. Craft
OBA No. 31126

Houston, TX 77010
713.951.9400
713.951.9212 (Fax)

Certificate of Service
This is to certify that on May 6, 2020 the undersigned mailed a copy of this filing via
Electronic Mail, to the following:
Bo Zou
7972 South Sheridan Road, Apt. 314
Tulsa, Oklahoma 74133
SENT VIA EMAIL: [email protected] ; [email protected]; and
[email protected]
Pro Se Plaintiff

Jessica L. Craft
2
TO PLAINTIFF’S THIRD REQUEST FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Provide emails between Mr. Randy Rogers and Mr.
David Close on June 11, 2019, involving in Plaintiff’s complaint and any internal investigation.
(E-mail must be screenshot and attached a copy of content).
RESPONSE: Defendant objects to Request No. 1 insofar as it requests information previously

produced. Defendant further objects to the directive on the format to produce electronically
stored information as improper, pursuant to Fed. R. Civ. P. 34(b)(2)(E)(iii) (“[a] party need not
produce the same electronically stored information in more than one form.”).
Defendant refers to Linde [Zou] 000270 - Linde [Zou] 000279, previously produced.
REQUEST FOR PRODUCTION NO. 2: Provide any correspondence, documents, emails,

text messages, records of phone calls between Mr. Randy Rogers and Mr. Jerry Gump from
January 14, 2019 to January 25, 2019; from April 10, 2019 to April 25, 2019; from May 13,
2019 to June 14, 2019; involving in Plaintiff’s complaint and any internal investigation. (E-mails
must be screenshot and attached a copy of content).

REQUEST FOR PRODUCTION NO. 3: In Plaintiff’s First Set of Requests of Interrogatories

No. 8, Defendant answered and stated that “Kenny Sharp and Dustin Dun are both tenured
Piping Engineers with design experience, .... “.
a. Please provide the promotion documents and e-mails for both Kenny Sharp and
Dustin Duncan as tenured Piping Engineers.
b. Please provide both Kenny Sharp and Dustin Duncan’s job responsibilities as
tenured Piping Engineers.
RESPONSE: Defendant objects to Request No. 3 because it is misleading, confusing, and

vague. The request requires the adoption of an improper assumption, that “tenured” means a
promotion.
Defendant refers to its response to Interrogatory No. 20. By way of further response, Defendant
refers to Linde [Zou] 000220 and Linde [Zou] 000290-Linde [Zou] 000293, previously
produced.
6
REQUEST FOR PRODUCTION NO. 4: Provide job position/job title and age for those
terminated employees whose age is lower than 40 years old in engineering department under
Jerry Gump’s supervision.
RESPONSE: Defendant refers to Linde [Zou] 000219 and Linde [Zou] 000292-Linde [Zou]
000293, previously produced.
REQUEST FOR PRODUCTION NO. 5: Provide any correspondence, emails, documents,

text messages, records of phone calls between Mr. Randy Rogers and Mr. David Close from May
13, 2019 to June 10, 2019, involving in Plaintiff’s complaint and any internal investigation. (E-
mail must be screenshot and attached a copy of content).

REQUEST FOR PRODUCTION NO. 6: Provide emails between Ms. Genie Churchill and
Ms. Cheryl Roberts of the third party National Corporate Housing-Tulsa, on October 15, 2018,
involving in Plaintiff’s apartment matter. (E-mails must be screenshot and attached a copy of
content).

produce the same electronically stored information in more than one form.”). Defendant further
objects to this Request as vague and confusing as it requests correspondence regarding
“Plaintiff’s apartment matter” without specificity and without explanation as to what Plaintiff is
referring to by using the phrase “Plaintiff’s apartment matter.” Finally, Defendant objects to this
Request because it requests documents not materially relevant to the claims or defenses in this
matter.
Defendant refers to Linde [Zou] 000029, previously produced.
REQUEST FOR PRODUCTION NO. 7: Provide emails between Ms. Amie Schlosberg of
Defendant and Ms. Stephanie Canada of the third party GEMINI ROSEMONT, on June 11,
2019, involving in Plaintiff’s complaints and car damage. (E-mails must be screenshot and
attached a copy of content).

“Plaintiff’s complaint and car damage” without specificity and without explanation as to what
Plaintiff is referring to by using the phrase “Plaintiff’s complaint.” Finally, Defendant objects to
7
this Request because it requests documents not materially relevant to the claims or defenses in
this matter.
Defendant refers to Linde [Zou] 000280- Linde [Zou] 000284, previously produced.
REQUEST FOR PRODUCTION NO. 8: Provide emails between Ms. Amie Schlosberg and
Ms. Deana Hoey on June 11, 2019, involving in Plaintiff’s complaints and car damage. (E-mails
must be screenshot and attached a copy of content).

“Plaintiff’s complaint and car damage” without specificity and without explanation as to what
Plaintiff is referring to by using the phrase “Plaintiff’s complaint.” Finally, Defendant objects to
this Request because it requests documents not materially relevant to the claims or defenses in
this matter.
Defendant refers to Linde [Zou] 000280- Linde [Zou] 000284, previously produced.
4823-2454-4953.1 104712.1001
8
EXHIBIT “4”
Bo Zou, §
§
Plaintiff §
§
vs. § NO. 4:19-CV-00554-JED-JFJ
§
§
Defendant. §

TO PLAINTIFF’S FOURTH REQUEST FOR PRODUCTION
Plaintiff’s Fourth Request for Production.
DEFENDANT'S OBJECTIONS AND RESPONSES TO PLAINTIFF'S FOURTH REQUESTS FOR PRODUCTION – PAGE 1
Dated: June 11, 2020 Respectfully submitted,
/s/ Jonathan G. Rector

Jonathan G. Rector
OBA No. 30691

2001 Ross Avenue
Dallas, TX 75201
214.880.8100
214.880.0181 (Fax)
And
Jessica L. Craft
OBA No. 31126

Houston, TX 77010
713.951.9400
713.951.9212 (Fax)

This is to certify that on June 11, 2020 the undersigned mailed a copy of this filing via
Bo Zou
SENT VIA EMAIL: [email protected]; [email protected]; and
[email protected]
Pro Se Plaintiff
/s/ Jonathan G. Rector

Jonathan G. Rector
GENERAL OBJECTIONS
The following general objections apply to each Request for Production and are hereby
incorporated by reference in response to each Request as if completely restated therein.
1. Defendant objects to Plaintiff’s requests for production to the extent the intended
subject matter or requests inquire, in whole or in part, into the communications between
attorneys and clients (or between or among clients or clients’ representatives and their lawyers’
representatives) made in confidence for the purpose of facilitating the rendition of professional
legal services, all of such communications are protected from discovery by the attorney-client
privilege.
subject matter or requests inquire, in whole or in part, into the mental impressions, conclusions,
opinions, or legal theories of Defendant’s attorneys or other representatives of Defendant
working to assist trial preparation or in anticipation of litigation, such is protected from
discovery by the work product privilege.
subject matter or requests inquire, in whole or in part, into medical-peer-review records or
medical-committee records of Defendants’ medical peer review committee, professional review
body, or medical committee, such is protected from discovery by the peer-review and medical-
committee privileges.
subject matter or requests inquire, in whole or in part, into written statements of potential
witnesses or parties, or for party communications made in connection with the investigation of
this lawsuit, or for any matter protected from disclosure by any other privilege, such is protected
from discovery by the Federal Rules of Evidence.
5. Defendant objects to Plaintiff’s requests for production to the extent that they seek
information regarding events outside the proper temporal scope or geographical scope of
discovery. Discovery should be limited to a reasonable time frame and reasonable geographic
area. Defendant objects to providing information concerning events that occurred outside of a
reasonable time frame and reasonable geographic area.
6. Defendant objects to Plaintiff’s requests to the extent they would require
production of documents protected by the physician-patient privilege or the Health Insurance
Portability and Accountability Act (“HIPAA”).
7. Defendant objects to Plaintiff’s interrogatories to the extent they would require
production of documents containing personal and confidential information regarding individuals
who are not parties in this lawsuit.
8. Defendant objects to Plaintiff’s interrogatories to the extent they seek production
of confidential, financial, or proprietary documents about employees, clients, or business
operations.
9. Defendant has made a good faith effort to interpret the written requests in a
common sense manner consistent with the issues in the litigation. To the extent that Plaintiff
believes that Defendant has placed a different or narrow construction of the language in a
particular request where this objection has been asserted, then Defendant objects to the request
on the grounds that it is vague and susceptible to differing interpretations, and on the grounds
that it is over broad and seeks more information than is reasonable in the context of the issues
and facts and this lawsuit.
10. Defendant objects to Plaintiff’s requests for production to the extent that
Plaintiff’s requests are vague, overbroad, unduly burdensome, seek information that is not
relevant to the claims or defenses of the parties and not reasonably calculated to lead to the
discovery of admissible evidence, and requires Defendant to take action beyond those required
by the Federal Rules of Civil Procedure.
11. Defendant objects to Plaintiff’s requests for production to the extent Plaintiff
seeks to require Defendant to produce documents not relevant, or not in its possession, custody,
or control.
12. Defendant objects to Plaintiff’s requests for production to the extent that they
require a narrative response and require Defendant to marshal the evidence. Defendant contends
that such requests are more appropriately areas for deposition inquiry.
The foregoing General Objections are made in response to every numbered Request for
Production in Plaintiff’s Fourth Set of Requests for Production to Defendant and are
incorporated into the following answers to each such Request, and each such answer is made
subject to the foregoing objections. In addition, by stating that any documents do not exist,
Defendant represents only that to Defendants’ knowledge those documents do not exist and that
those documents are not in the Defendants’ possession, custody, or control.
REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Provide documents and communications involving
in other reasons for Plaintiff's termination except the reason that Plaintiff's position was
eliminated.
RESPONSE: Defendant objects to this Request as vague and confusing, in that it asks
Defendant to state “provide documents and communications involving in other reasons for
Plaintiff’s termination except the reason that Plaintiff’s position was eliminated.” As stated
previously in other discovery responses, Plaintiff’s position was eliminated as part of the
reduction-in-force. By way of further response, Defendant incorporates its response to
Interrogatory No. 6. Defendant further refers Plaintiff to Linde [Zou] 000220 and Linde [Zou]
000290-91, previously produced. See Linde [Zou] 000220 and Linde [Zou] 000290-91,
previously produced. Defendant is not withholding documents pursuant to its objections.
REQUEST FOR PRODUCTION NO. 2: Provide documents to show the starting date of the
new project LR 6400 and LRSV 200 project.
RESPONSE: Defendant objects to this Request as it seeks documents that are neither relevant
to the allegations in this case nor reasonably calculated to lead to the discovery of admissible
evidence. Further, Defendant objects to the Request on the grounds and to the extent that it
seeks private, proprietary, confidential, and/or sensitive business information, or information that
is otherwise protected as a trade secret.
Defendant states that LR 640 started on or about June 2019 and LRSV 200 started on or
about August 2019. By way of further response, Defendant will produce the piping
specifications, subject to a protective order, pursuant to the Court’s May 19, 2020 Order.
REQUEST FOR PRODUCTION NO. 3: Provide the promotion documents and e-mails for
both Kenny Sharp and Dustin Duncan as Piping Engineers.
RESPONSE: Defendant objects to Request No. because it is misleading, confusing, and vague.
The interrogatory requires the adoption of an improper assumption, that “tenured” means a
promotion.
Defendant will produce documents showing Kenney Sharp and Dustin Duncan’s
employment history with Linde. Defendant is not withholding documents pursuant to its
objections.
REQUEST FOR PRODUCTION NO. 4: Provide both Kenny Sharp and Dustin Duncan's job
responsibilities as Piping Engineers.
RESPONSE: Defendant will produce copies of the Job Description for Kenney Sharp and
Dustin Duncan’s positions with Linde during the relevant time period. Defendant is not
withholding documents pursuant to its objections.
REQUEST FOR PRODUCTION NO. 5: Provide documents or communications between
Defendant and ICC Group Inc. (ICC) except the email ICC contacted the Defendant on February
24, 2020.
RESPONSE: Defendant objects to Request No. 5 because the request is irrelevant and beyond
the scope of Fed. R. Civ. P. Rule 26(b)(1), as the Court has previously held. See Dkt. No. 37, p
10 (holding that Plaintiff’s request for post-employment communication between ICC and others
was an “overly speculative fishing expedition for information that may or may not exist and that
has no discernible relevance to the current litigation.”). Further, Plaintiff cannot use the
discovery process as a fishing expedition to continue harassing Defendant and other parties.
Defendant is withholding documents pursuant to its objections.
REQUEST FOR PRODUCTION NO. 6: Provide the e-mail Plaintiff sent to the process
engineer Andrew Mileur [sic] at Linde Tulsa office on August 6, 2020 [sic] (PDF format printed
as the format in Linde [Zou] 000269).
RESPONSE: This request is irrelevant, unduly burdensome, and not reasonably calculated to
lead to admissible evidence.
Defendant is in the process of reviewing its files and will produce the responsive
documents if it is in its possession, custody or control. Defendant is not withholding documents
pursuant to its objections.
EXHIBIT “5”
Bo Zou, §
§
Plaintiff §
§
vs. § NO. 4:19-CV-00554-JED-JFJ
§
§
Defendant. §

TO PLAINTIFF’S FIFTH REQUEST FOR PRODUCTION
Plaintiff’s Fifth Request for Production.
DEFENDANT 'S OBJECTIONS AND RESPONSES TO PLAINTIFF 'S FIFTH REQUESTS FOR PRODUCTION – PAGE 1
Dated: July 22, 2020 Respectfully submitted,

Jonathan G. Rector
OBA No. 30691

2001 Ross Avenue
Dallas, TX 75201
214.880.8100
214.880.0181 (Fax)
And
Jessica L. Craft
OBA No. 31126

Houston, TX 77010
713.951.9400
713.951.9212 (Fax)

This is to certify that on July 22, 2020 the undersigned mailed a copy of this filing via
Bo Zou
SENT VIA EMAIL: [email protected]; [email protected]; and
[email protected]
Pro Se Plaintiff

Jessica L. Craft
REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Provide e-mails between Plaintiff and Plaintiff’s
supervisor Jerry Gump from April 28, 2019 to August 7, 2019.
RESPONSE: Defendant objects to this Request as duplicative, vague, facially overbroad, and
not proportional to the needs of the case, considering all Rule 26(b)(1) factors. The request, as
phrased, is irrelevant and an overly broad fishing expedition that will result in production of
significant amounts of irrelevant business communications. Defendant will reasonably narrow
Plaintiff’s request to emails sent between Plaintiff and Jerry Gump insofar as they relate to
Plaintiff’s May 2019 complaint, Plaintiff’s job performance, and the August 2019 reduction-in-
force. By way of further response, Defendant refers Plaintiff to documents previously produced.
Defendant will continue to supplement emails pertaining to the narrowed scope. Defendant is not
withholding any documents.
REQUEST FOR PRODUCTION NO. 2: Provide e -mails between Plaintiff and young
engineer Kenny Sharp from April 28, 2019 to August 7, 2019.
Plaintiff’s request to emails sent between Plaintiff and Kenny Sharp insofar as they relate to
Plaintiff’s May 2019 complaint, Plaintiff’s job performance, and the August 2019 reduction-in-
force. By way of further response, Defendant refers Plaintiff to documents previously produced.
Defendant will continue to supplement emails pertaining to the narrowed scope. Defendant is not
withholding any documents.
REQUEST FOR PRODUCTION NO. 3: Provide e -mails between Plaintiff and young
engineer Dustin Duncan from June 1, 2019 to July 1, 2019.
Plaintiff’s request to emails sent between Plaintiff and Kenney Sharp insofar as they relate to
Plaintiff’s May 2019 complaint and Plaintiff’s job performance. By way of further response,
Defendant refers Plaintiff to documents previously produced. Defendant will continue to
supplement emails pertaining to the narrowed scope. Defendant is not withholding any
documents.
REQUEST FOR PRODUCTION NO. 4: Provide e -mails between Plaintiff and Terry
Albrecht from June 1, 2019 to July 26, 2019.
Plaintiff’s request to emails sent between Plaintiff and Terry Albrecht insofar as they relate to
documents.
REQUEST FOR PRODUCTION NO. 5: Provide e-mails between Plaintiff and Kelly
Leitch, from March 1, 2019 to June 20, 2019.
Plaintiff’s request to emails sent between Plaintiff and Kelley Leitch insofar as they relate to
documents.
REQUEST FOR PRODUCTION NO. 6: Provide internal investigation reports made by
Deana Hoey for Plaintiff’s complaints on May 6 & 12, 2020.
RESPONSE: This request assumes facts not in evidence and is duplicative of previously-issued
requests for production. Defendant refers to Linde’s investigation file as to Plaintiff’s
Complaints, which are contained at Linde [Zou] 000269 – 000289, Linde [Zou] 000295- 000296,
and Linde [Zou] 001669-001672, previously produced, and Linde [Zou] 002127-002128, Linde
[Zou] 002154-002157. After diligent review by Defendant, Defendant states there are no other
responsive documents. Defendant is not withholding any documents.
REQUEST FOR PRODUCTION NO. 7: Provide PRIV 0001, 0002 listed on Defendant’s
Privilege Log. These organization charts made on September 5, 2019 are never work
product privilege.
RESPONSE: This request is duplicative of previously-issued requests for production and seeks
information in violation of the Court’s May 19, 2020 Order [Dkt. No. 37]. The request seeks
information that is irrelevant, confidential, and not reasonably calculated to lead to admissible
evidence. Defendant refers to Linde [Zou] 000294, previously produced in accordance with the
May 19, 2020 Order. Defendant is withholding documents as set out in the Privilege Log,
previously produced.
4817-4469-9587.1 104712.1001
12. If you are unable to answer fully any of these requests, you must answer them to the
fullest extent possible, specifying the reason(s) for your inability to answer the remainder and
stating whatever information, knowledge, or belief you have concerning the unanswerable
portion.
13. For each request and subpart of each request, If the information furnished in your
answer is not within your personal knowledge, identify each person to whom the information is a
matter of personal knowledge, if known.
14. Each request is to be regarded as continuing to the extent permitted under the Federal
Rules of Civil Procedure and/or Local Rules of this Court. If, subsequent to serving an answer to
any request and prior to the trial of this Action, you obtain or become aware of additional
information pertaining to that request, you shall serve a supplement sworn answer setting forth
such information.
15. If you object to fully identifying an oral communication because of a privilege, you
must nevertheless provide the following information:
a. the nature of the privilege claimed (including work product);
b. if the privilege is being asserted in connection with a claim or defense governed by state
law, the state privilege rule being invoked;
c. the date of the oral communication;
d. the place where it was made, the names of the persons present while it was made, and, if
not apparent, the relationship of the persons present to the declarant; and
e. the general subject matter of the oral communication.
PLAINTIFF’S FIFTH SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS--

SUPPLEMENTAL
1. Please provide all documents obtained/received by way of subpoena or deposition on written

questions, relating to this Lawsuit, Plaintiff, or the factual or legal claims in the Complaint.
Response:
3
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Redacted
Piping specifications for Husky I (2110A5D2)
Linde Document Number Document Description Issue Issue Date BY CHECKED APPROVED
&AFA5D2-000-R-SS Piping Specification Index Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/22/2019
001.001 (KRS) (MGD) (BW)
&AFA5D2-000-R-SS A10 150# General Process and Kenny Sharp Martin Dryden Brent Wiruth
Utility Piping Design and 1.0 5/22/2019 (KRS) (MGD) (BW)
Material Specification
&AFA5D2-000-R-SS A13 150# Heat Medium Piping Kenny Sharp Martin Dryden Brent Wiruth
Design and Material 1.0 5/22/2019 (KRS) (MGD) (BW)
Specification
&AFA5D2-000-R-SS A20 150# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
Systems Piping Design and 1.0 5/22/2019 (KRS) (MGD) (BW)
&AFA5D2-000-R-SS A30 150# General Process, Kenny Sharp Martin Dryden Brent Wiruth
Corrosive Service Piping Design 1.0 5/22/2019 (KRS) (MGD) (BW)
and Material Specification
&AFA5D2-000-R-SS A40 150# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
Process-Low Temperature (KRS) (MGD) (BW)
1.0 5/22/2019
Service (To -50F) Piping Design
&AFA5D2-000-R-SS A65 150# General Process, Kenny Sharp Eli McDaniel Jake Rogers
2.0 9/18/2019
Stainless Steel for Severe (KRS) (ETM) (JR)
Linde [Zou] 000302

CONFIDENTIAL
Corrosive Service Piping Design
&AFA5D2-000-R-SS A65 150# General Process, Kenny Sharp Martin Dryden Brent Wiruth
Stainless Steel for Severe (KRS) (MGD) (BW)
1.0 5/22/2019
&AFA5D2-000-R-SS A90 150# Flare and Drain Systems Kenny Sharp Martin Dryden Brent Wiruth
Piping Design and Material 1.0 5/22/2019 (KRS) (MGD) (BW)
Specification
&AFA5D2-000-R-SS B10 300# General Process and Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS B10 300# General Process and Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS B20 300# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS B40 300# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/22/2019
&AFA5D2-000-R-SS B50 300# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
Process-Semi Cryogenic (KRS) (MGD) (BW)
Service (to -175F) Piping 1.0 5/22/2019
Design and Material
Specification
&AFA5D2-000-R-SS B60 300# Refrigeration and Process Kenny Sharp Martin Dryden Brent Wiruth
Cryogenic Service (to -325F) (KRS) (MGD) (BW)
1.0 5/22/2019
Piping Design and Material
Specification
&AFA5D2-000-R-SS C10 600# General Process Piping Kenny Sharp Martin Dryden Brent Wiruth
Specification
&AFA5D2-000-R-SS C20 600# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS C40 600# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/22/2019
Linde [Zou] 000303

CONFIDENTIAL
&AFA5D2-000-R-SS C50 600# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
Design and Material
Specification
&AFA5D2-000-R-SS C60 600# Refrigeration and Process Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/22/2019
Specification
&AFA5D2-000-R-SS C65 600# General Process Severe Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS D20 900# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5D2-000-R-SS I11 150# Galvanized Utility Service Kenny Sharp Martin Dryden Brent Wiruth
Specification
Piping specifications for Husky II, Re-designated as Cowboy II (2110A5D2)
&AFA5DR-000-R-SS Piping Specification Index Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
001.001 (KRS) (MGD) (BW)
&AFA5DR-000-R-SS A10 150# General Process and Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS A13 150# Heat Medium Piping Kenny Sharp Martin Dryden Brent Wiruth
Specification
&AFA5DR-000-R-SS A20 150# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS A30 150# General Process, Kenny Sharp Martin Dryden Brent Wiruth
Linde [Zou] 000304

CONFIDENTIAL
&AFA5DR-000-R-SS A40 150# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
&AFA5DR-000-R-SS A65 150# General Process, Kenny Sharp Eli McDaniel Jake Rogers
Stainless Steel for Severe (KRS) (ETM) (JR)
2.0 9/18/2019
&AFA5DR-000-R-SS A65 150# General Process, Kenny Sharp Martin Dryden Brent Wiruth
Stainless Steel for Severe (KRS) (MGD) (BW)
1.0 5/23/2019
&AFA5DR-000-R-SS A90 150# Flare and Drain Systems Kenny Sharp Martin Dryden Brent Wiruth
Specification
&AFA5DR-000-R-SS B10 300# General Process and Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS B10 300# General Process and Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS B20 300# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS B40 300# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
&AFA5DR-000-R-SS B50 300# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
Design and Material
Specification
&AFA5DR-000-R-SS B60 300# Refrigeration and Process Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
Specification
Linde [Zou] 000305

CONFIDENTIAL
&AFA5DR-000-R-SS C10 600# General Process Piping Kenny Sharp Martin Dryden Brent Wiruth
Specification
&AFA5DR-000-R-SS C20 600# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS C40 600# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
&AFA5DR-000-R-SS C50 600# Refrigeration and Kenny Sharp Martin Dryden Brent Wiruth
Design and Material
Specification
&AFA5DR-000-R-SS C60 600# Refrigeration and Process Kenny Sharp Martin Dryden Brent Wiruth
1.0 5/23/2019
Specification
&AFA5DR-000-R-SS C65 600# General Process Severe Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS D20 900# Sulfinol and Amine Kenny Sharp Martin Dryden Brent Wiruth
&AFA5DR-000-R-SS I11 150# Galvanized Utility Service Kenny Sharp Martin Dryden Brent Wiruth
Specification
Piping specifications for GSP-200 Stock Plant (2110A5EG2)
&AFA5EG-000-R-SS Piping Specification Index Kenny Sharp Martin Dryden Adam Milad
1.0 4/17/2019
1001.001 (KRS) (MGD) (AM)
&AFA5EG-000-R-SS A10 150# General Process and Kenny Sharp Martin Dryden Adam Milad
Utility Piping Design and 1.0 4/17/2019 (KRS) (MGD) (AM)
&AFA5EG-000-R-SS A40 150# Refrigeration and Not issued. George Zou Not Checked Not
1.1
Process-Low Temperature Draft Status Approved
Linde [Zou] 000306

CONFIDENTIAL
&AFA5EG-000-R-SS A40 150# Refrigeration and Kenny Sharp Martin Dryden Adam Milad
Process-Low Temperature (KRS) (MGD) (AM)
1.0 4/17/2019
&AFA5EG-000-R-SS A90 150# FLARE and DRAIN George Zou Not Checked Not
Not issued.
SYSTEMS 150# FLARE and 1.1 Approved
Draft Status
DRAIN SYSTEMS
&AFA5EG-000-R-SS A90 150# FLARE and DRAIN Kenny Sharp Martin Dryden Adam Milad
SYSTEMS 150# FLARE and 1.0 4/17/2019 (KRS) (MGD) (AM)
DRAIN SYSTEMS
&AFA5EG-000-R-SS B10 300# GENERAL PROCESS and Kenny Sharp Martin Dryden Adam Milad
UTILITIES PIPING DESIGN AND 1.0 4/17/2019 (KRS) (MGD) (AM)
MATERIAL SPECIFICATION
&AFA5EG-000-R-SS B40 300# REFRIGERATION and Kenny Sharp Martin Dryden Adam Milad
PROCESS – LOW TEMPERATURE (KRS) (MGD) (AM)
SERVICE (to -50°F) PIPING 1.0 4/17/2019
DESIGN AND MATERIAL
SPECIFICATION
PROCESS – SEMICRYOGENIC (KRS) (MGD) (AM)
DESIGN AND MATERIAL
SPECIFICATION
PROCESS – CRYOGENIC SERVICE (KRS) (MGD) (AM)
1.0 4/17/2019
(to -325) PIPING DESIGN AND
&AFA5EG-000-R-SS C10 600# GENERAL PROCESS PIPING Kenny Sharp Martin Dryden Adam Milad
DESIGN AND MATERIAL 1.0 4/17/2019 (KRS) (MGD) (AM)
SPECIFICATION
&AFA5EG-000-R-SS C40 600# REFRIGERATION AND Kenny Sharp Martin Dryden Adam Milad
PROCESS – LOW TEMPERATURE (KRS) (MGD) (AM)
DESIGN AND MATERIAL
SPECIFICATION
1.0 4/17/2019
PROCESS SEMI-CRYOGENIC (KRS) (MGD) (AM)
Linde [Zou] 000307

CONFIDENTIAL
SERVICE (to -175°F) PIPING
DESIGN AND MATERIAL
SPECIFICATION
PROCESS CRYOGENIC SERVICE (KRS) (MGD) (AM)
1.0 4/17/2019
(to -325°F) PIPING DESIGN AND
Piping specifications for 6400 HP Refrigeration System – LR6400 (91PM0028)
&AF0028-000-R-SS Piping Specification Index Kenny Sharp Eli McDaniel Kathryn
1.0 9/05/2019
1001.001 (KRS) (ETM) Green (KG)
&AF0028-000-R-SS A10 150# General Process and Kenny Sharp Eli McDaniel Kathryn
Utility Piping Design and 1.0 9/05/2019 (KRS) (ETM) Green (KG)
&AF0028-000-R-SS A13 150# Heat Medium Piping and Kenny Sharp Eli McDaniel Kathryn
1.0 9/05/2019
Design Specification (KRS) (ETM) Green (KG)
&AF0028-000-R-SS A40 150# Refrigeration and Kenny Sharp Eli McDaniel Kathryn
Process-Low Temperature (KRS) (ETM) Green (KG)
1.0 9/05/2019
Service (To -50F) Piping and
Design Specification
&AF0028-000-R-SS B10 300# General Process and Kenny Sharp Eli McDaniel Kathryn
Utilities Piping and Design 1.0 9/05/2019 (KRS) (ETM) Green (KG)
Specification
&AF0028-000-R-SS B40 300# Refrigeration and Kenny Sharp Eli McDaniel Kathryn
1.0 9/05/2019
&AF0028-000-R-SS B60 300# Refrigeration and Kenny Sharp Eli McDaniel Kathryn
Process-Cryogenic Service (To - (KRS) (ETM) Green (KG)
1.0 9/05/2019
50F) Piping and Design
Specification
&AF0028-000-R-SS C10 600# General Process Piping Kenny Sharp Eli McDaniel Kathryn
1.0 9/05/2019
and Design Specification (KRS) (ETM) Green (KG)
&AF0028-000-R-SS C40 600# Refrigeration and Kenny Sharp Eli McDaniel Kathryn
1.0 9/05/2019
Linde [Zou] 000308

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EXHIBIT “9”
EXHIBIT “10”
EXHIBIT “11”
EXHIBIT “12”
EXHIBIT “13”
Redacted
Redacted
Linde [Zou] 000141
EXHIBIT “14”
Responses 6/12/19: George Zou
Thank you for the detailed information you provided us on 5/10/19. We take
ethics reports very seriously here at Linde. We encourage our employees to
report any unethical issues. We did a complete investigation on each incident you
pointed out.
• We do not feel that the Crestwood and XTO project mistakes were
purposely done. Ball valves was a new process to Linde and we all are here
to learn and grow. Kenny Sharp and his performance will be addressed as
we see appropriate
• WE appreciate the help you provided RTFE for the cryogenic service – it was
greatly appreciated
• Adam Milad was promoted as we deem appropriate for the business and
appreciate your concern but feel how we handle Adam and his position is a
management decision
• The only training we have uncovered that was cancelled was the new hire
training or Linde process and systems – this was cancelled for everyone
• The bidding process and bid received with BWFS had nothing to do with
Adam Milad. WE have very strict procedures and when it comes to our
procurement and proposal process
• Jerry Gump does not know or have a connection with Carlos Hernandez or
BWFS
• You and Adam’s previous relationship has nothing to do with Linde and our
processes
Again, thank you for bringing this to us. If you have any other specific information
you need us to investigate we will be glad to assist you.
Thanks
Linde [Zou] 000289

EXHIBIT “15”
David,
I write you the following issues I saw and experienced since I joined LENA Tulsa last October, and
hope that Linde could pay attention to the issues and advance toward great goals.
1. I don't think that engineering manager Jerry Gump is fair in his job. His ethics is in question,
either. The reasons are as following:
a. In LENA'S Crestwood and XTO project, the piping design engineer Kenney Sharp, who is
responsible for materials and project piping specs, made a very big mistaken. All the ball
valves were designed with short pattern type. However, the valves information was issued to
procurement department with long pattern ball valves. After the long pattern ball valves were
purchased and shipped to Linde, and all the piping isometric drawings were issued to the
client. Linde found the mistaken at that time. Linde must re-update piping isometric drawings
and re-issue the isometric drawings to the client due to no choice in replacing long pattern
ball valves with short pattern valves. It not only costed piping designers in LENA Tulsa and
Houston a lot of labors but also let LENA lose trust from the client. However, Jerry Gump
and former head of operation Art Thompson never punished Kenney Sharp, but rewarded
Kenney Sharp on April 25, 2019. Jerry Gump is unfair in his job.
b. I finished LENA'S piping technical specs (see attached e-mail and some evidences) on Feb.
21, 2019 based on LENA'S requirements for GSP (stock plant) project However, Kenny
Sharp wanted to hide or cover his mistaken in cryogenic ball valve seat materials and other
materials existing in Crestwood and XTO project, and misguided, lied and cheated manger,
piping group lead and other people because Kenny Sharp never wanted to correct the "7
mistaken in Crestwood and XTO piping specs. I told some people in bi-weekly meeting on
March 13, 2019 that cryogenic ball valve seat material RTFE is wrong for cryogenic service
and provided some evidences to Jerry Gump on March 14, 2019. Jerry Gump finally accepted
my suggestions and commanded Kenny Sharp to combine my suggestions into XTO piping
specs on March 27, 2019. However, Kenny Sharp only took some modification, and told me
that Martin Dryden said that all the modifications would be done for later projects, not this
time. But, it's not true. On April 17, 2019, Kenny Sharp used Martin Dryden's name and his
name to issue stock plant piping specs, whose most modifications for cryogenic valves
come from my finished technical specs on Feb. 21, 2019. Unfortunately, there is still
mistaken in the stock plant piping specs issued by Kenny Sharp because Kenny Sharp only
took most of specs I finished on Feb. 21, 2019. On April 29, 2019, Kenny Sharp let me copy
XTO specs as Husky 1 & 2 specs. I found that there is mistaken in XTO specs. I refused to
put my name on Husky 1 & 2. Kenny Sharp agreed to modify some mistaken but still keep
some that no big impact to project. On April 18, 2019, I told procurement manager Randy
Roger that Kenny Sharp's issues when we talked about ball valves. However, Randy Roger
immediately reported to Art Thompson. And then, Art Thompson told Jerry Gump. Jerry
Gump still rewarded Kenny Sharp in company employee party on April 25, 2019. 1 think that
Jerry Gump challenged Linde' s fairness using his manager power. Kenny Sharp made big
mistaken and purposed not to correct the mistaken is not punished but rewarding. It really
happened in Linde today. How could Kenny Sharp misguide, lie even cheat other people, and
never take any responsibility for his mistaken? The reason is that Jerry Gump supports him.
So, Kenny Sharp can do everything as he wants to do, and ignore any LENA's requirements
and regulations. Where is Jerry Gump's fairness and ethics? I think that Jerry Gump is in
professional misconduct.
(Note: I can provide ai ft© eMdeneesftfr Kenny Sharp's lie and cheat.)
Redacted
Linde [Zou] 000285
EXHIBIT “16”
Redacted
Linde [Zou] 000029
EXHIBIT “17”
From: Deana Hoey
Sent: Tuesday, June 11, 2019 3:31 PM
To: Amie Schlosberg
Cc: Aaron Watson
Subject: RE: OWP-Linde- Incident Report- employee
Hello Amie
Thank you. I will follow up with Mr. Zou on the below information
Deana Hoey
From: Amie Schlosberg
To: Deana Hoey <[email protected]>
Cc: Aaron Watson <[email protected]>
Subject: FW: OWP‐Linde‐ Incident Report‐ employee
Hello Deana,
In early May, I was contacted by our Building Management company, Gemini Rosemont, to inform me about an incident
with one of our employees, George Zou. George had contacted building security to report that his vehicle had been
damaged in the parking garage and he wanted permission to park in visitor parking, as well as to have Rosemont pay for
the damages. Of course, without any witnesses or evidence that the damage actually occurred in the parking garage,
there isn’t really anything that Rosemont can do, but George continues to contact them for an “update”.
I haven’t spoken with George about this, but wondered if you can have a conversation with him to let him know that
Rosemont is not responsible for damage to vehicles in the parking garage per the attached sign that’s posted at the
entrance to the parking garage?
Please see the email messages below as well as a copy of the incident report that the building security took from
George. If you need any additional information or have questions, please don’t hesitate to contact me.
Thank you,
Amie Schlosberg
Executive Assistant to Carlos Conerly
Facilities Coordinator
Linde Engineering North America
6100 S. Yale Avenue, Suite 1200 | Tulsa, OK 74136 USA
Dir: +1.918.477.1212
[email protected] | www.leamericas.com
From: Stephanie Canada <[email protected]>
To: Amie Schlosberg <[email protected]>; Scott Mitchell <[email protected]>
Cc: Wade Bell <[email protected]>
Subject: RE: OWP‐Linde‐ Incident Report‐ employee
1
Redacted
Linde [Zou] 000280

*** Please note the message below originated on the Internet. Please use caution when replying or opening
links or attachments. ***
He hasn’t said specifically; he asks for an update.

I believe we have provided everything we can provide and there is nothing more we can do…

Thanks so much for your help, Amie!

Stephanie Canada
Senior Tenant Relations Manager, Warren Place

GEMINI ROSEMONT
COMMERCIAL REAL ESTATE

6100 South Yale Avenue, Suite 390 | Tulsa, OK 74136
918.492.3400 main| 918.859.2741 cell |918.271.5143 fax to email
[email protected]
geminirosemont.com

From: Amie Schlosberg <[email protected]>
To: Stephanie Canada <[email protected]>; Scott Mitchell <[email protected]>

Hi Stephanie,

No, I didn’t realize it was continuing. When he calls, he wants to know when someone will take care of the repairs?
What specifically does he ask for an update on?

I will speak to his manager and our HR department about this. Thank you for letting me know.

Thank you,

Amie Schlosberg

Dir: +1.918.477.1212

From: Stephanie Canada <[email protected]>
To: Scott Mitchell <[email protected]>; Amie Schlosberg <[email protected]>
2
Redacted
Linde [Zou] 000281
Importance: High

Good afternoon Amie,

Mr. Zou has called our office a couple of times in the last month or so, trying to get an update – has anyone at Linde
spoken with him about this?

Unfortunately, without witnesses or evidence, there is nothing more we can do.

Will you, or someone else within Linde, please speak with him regarding this incident?

Let me know if you have any questions.

Thank you!

Stephanie Canada
Senior Tenant Relations Manager, Warren Place

GEMINI ROSEMONT

6100 South Yale Avenue, Suite 390 | Tulsa, OK 74136
918.492.3400 main| 918.859.2741 cell |918.271.5143 fax to email
[email protected]
geminirosemont.com

From: Scott Mitchell <[email protected]>
Sent: Wednesday, May 8, 2019 4:02 PM
To: Amie Schlosberg <[email protected]>
Cc: Stephanie Canada <[email protected]>; Wade Bell <[email protected]>

Hi, Amie‐
While we do have cameras covering strategic entry/exit points, etc. in the garage and parking areas, it would be
prohibitive to attempt to cover all of the parking spaces in the garage. Unfortunately, the area where Mr. Zou was
parked isn’t covered. Trying to ascertain exactly what happened and why, is very challenging. It’s not that we dispute
Mr. Zou’s contention that it was intentionally damaged here; we would explore the reasons why it happened as this
occurrence is quite rare here. Has there been any type of confrontation or conflict lately? There have been times when
damage like this has occurred off site in an individual’s neighborhood, or at the grocery store, etc.; then they’ve noticed
it here and assumed this is where the damage occurred.
Mr. Zou stated to Security that we should have cameras that cover every parking space ( 1,770 spaces in the One
Warren garage ). Security did inform him that parking in Visitor Parking would not be acceptable and took his statement
for the Incident Report, but Security is not authorized to discuss whom would be the responsible party for damages.
There is signage posted at the entrance to the parking garage which states the rules of responsibility for those parking in
the garage.
Please contact me with any further questions or concerns.
Thank you,
3
Redacted
Linde [Zou] 000282

Scott A. Mitchell, RPA
Senior Property Manager
Warren Place

GEMINI ROSEMONT

6100 S. Yale Ave., Suite 390 | Tulsa, OK 74136
918.492.3400 main | 918.232.6088 cell
[email protected]
geminirosemont.com

From: Amie Schlosberg <[email protected]>
Sent: Wednesday, May 08, 2019 8:31 AM
To: Scott Mitchell <[email protected]>

Good morning Scott,

Thank you for alerting me to the situation with Mr. Zou. We had another incident last year when an employee’s vehicle
was stolen and we had video footage of the incident. Are there any video cameras in the area that might have caught
the incident to allow us to contact the other party? I assume the security team advised Mr. Zou that it is not acceptable
to park in the visitor parking lot. I would imagine they also told Mr. Zou that the building management company cannot
be responsible for the damage. Can you please confirm?

Thank you,

Amie Schlosberg

Dir: +1.918.477.1212

From: Scott Mitchell <[email protected]>
Sent: Tuesday, May 7, 2019 3:13 PM
To: Amie Schlosberg <[email protected]>
Subject: OWP‐Linde‐ Incident Report‐ employee

4
Redacted
Linde [Zou] 000283
Hi, Amie‐
Our lobby security guard was contacted by one of your employees, Bo Zou, about damage to his vehicle. Bo believes that
this damage occurred in the One Warren Parking garage. A copy of the Incident Report is attached.
While it is unfortunate that Mr. Zou has incurred damage to his vehicle, we have no way of verifying that the damage did
occur in the parking garage. Per terms of the Lease we cannot be held responsible for damage to personal property. I
would recommend Mr. Zou contact his insurance carrier for a possible claim.
Please contact me with any questions regarding this issue.
Thank you,

Scott A. Mitchell, RPA
Senior Property Manager
Warren Place

GEMINI ROSEMONT

6100 S. Yale Ave., Suite 390 | Tulsa, OK 74136
918.492.3400 main | 918.232.6088 cell
[email protected]
geminirosemont.com

The information contained in this email and any attachments may be confidential and is provided solely for the use of
the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution,
or use of this e‐mail, its attachments or any information contained therein is unauthorized and prohibited. If you have
received this in error, please contact the sender immediately and delete this e‐mail and any attachments. No
responsibility is accepted for any virus or defect that might arise from opening this e‐mail or attachments, whether or
not it has been checked by anti‐virus software...
The information contained in this email and any attachments may be confidential and is provided solely for the use of
the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution,
or use of this e‐mail, its attachments or any information contained therein is unauthorized and prohibited. If you have
received this in error, please contact the sender immediately and delete this e‐mail and any attachments. No
responsibility is accepted for any virus or defect that might arise from opening this e‐mail or attachments, whether or
not it has been checked by anti‐virus software...
5
Redacted
Linde [Zou] 000284
EXHIBIT “18”
Case 4:19-cv-00554-JED-JFJ Document 19-1 Filed in USDC ND/OK on 03/04/20 Page 2 of 2
Rector, Jonathan
From: David Nijhawan <[email protected]>

Sent: Monday, February 24, 2020 12:54 PM
To: Rector, Jonathan; Craft, Jessica
Cc: Jennifer Bean; David Nijhawan
Subject: George Zu - Subpoena
Attachments: Subpoena to ICC.pdf
[EXTERNAL E-MAIL]
Jessica/Jeff –

I hope you are well. My name is David Nijhawan, and I am in house counsel at ICC. We received the attached subpoena
from a party adverse to you. It looks, from pacer, that he filed a civil suit against your client, Linde, in October and refiled
on 1/15/20.

We view this subpoena as too short of a time window, requires us to produce documents (which there are none b/c of
the vagueness of the subpoena), extremely overbroad, irrelevant to anything pertaining to us, and subjects us to undue
burden.

We plan to either object to it or hire outside counsel to quash it. We don’t have contacts in Oklahoma that I’m aware of
to hire as counsel either.

Let me know your thoughts on this – perhaps this is something you might want to move to quash?

David

David Raj Nijhawan, Esq.  Director of Strategic Transactions
Cell 503.449.3057  [email protected]

390 S. Redwood Street  Canby OR, 97013  www.icc-nw.net

1
Rector, Jonathan

Sent: Monday, February 24, 2020 5:00 PM
To: Craft, Jessica; Rector, Jonathan; [email protected]
Cc: Jennifer Bean; Janica McEndollar; Eric Raibley; John Vinti; David Nijhawan
Subject: Subpoena to ICC - George Zou/Bo Zou
Attachments: Subpoena to ICC.pdf
Importance: High
[EXTERNAL E-MAIL]
Mr. Zou –

We received your notice of subpoena. My name is David Nijhawan, and I am general counsel at ICC. Please
communicate with me directly.

We object to the subpoena on several grounds pursuant to the Federal Rules of Civil Procedure. Moreover, as you are
aware, counsel for the adverse party in your lawsuit objects as well. If further action continues on your part, we do
intend to file a motion to quash.

The gravamen of our objections rests in FRCP 45 and its applicable provisions:

1) The request is overbroad and not narrowly tailored
2) The method of service remains flawed (we never received a paper copy)
3) The time limit for the request remains deficient
4) You violated the civil procedure rules by not notifying your adverse party through their counsel
5) Documents you request remain wholly unrelated to your lawsuit against Linde Engineering
6) Responding to this would cause undue hardship on us to produce due, primarily, to the scope
7) It would require us to produce documents over 100 miles away

Sincerely,

David



1
Rector, Jonathan

Sent: Tuesday, February 25, 2020 3:19 PM
To: Z George; Rector, Jonathan; Craft, Jessica
Cc: David Nijhawan
Subject: RE: 回复: Subpoena to ICC - George Zou/Bo Zou
[EXTERNAL E-MAIL]
Mr. Zou:

ICC is only required to serve you with written objections to your subpoena under Fed. R. Civ. P. 45(d)(2)(B). ICC provided
these objections to you by email on February 24, 2020.

Further, your email contains language that is clearly threatening and harassing to ICC and its employees. Cease and
desist from any further email communication with myself or ICC employees, or ICC will take all appropriate legal
action. If you have any additional questions about the subpoena or ICC’s response to that subpoena, please put those
questions in writing and send them to my attention via US mail at the following address:

390 S. Redwood Street
Canby, OR 97013

Thanks.



From: Z George <[email protected]>
Sent: Tuesday, February 25, 2020 8:51 AM
To: David Nijhawan <dnijhawan@icc‐nw.net>
Cc: Jennifer Bean <jbean@icc‐inc.net>; Janica McEndollar <jmcendollar@icc‐inc.net>; Eric Raibley <eraibley@icc‐
inc.net>; John Vinti <jvinti@icc‐nw.net>
Subject: 回复: Subpoena to ICC ‐ George Zou/Bo Zou
Mr. David,
Please file a motion to quash in Court this week by you or the adverse party in my lawsuit. I shall see whether
Judge will support your motion.
I hereby need to remind ICC and you again not to make a risk to help other third parties against Federal Law or
State Law. Otherwise, ICC will experience a big trouble in lawsuit. Also, I don't want to see anybody is put to
jail or his/her whole life is destroyed in helping any third parties against law.
Opposing Party contacted my former employers, former clients and other agencies without my permission had
been against Federal Law and Law of State of Oklahoma.
1
As an attorney, you know whether ICC and some ICC employees have put a leg in illegal actions. I have hired
an investigation agency starting to investigate all illegal actions against me in my employment record, IRS,
Social Security, local and Federal courts, etc. I shall give opposing party a "lethal" strike in my lawsuit in the
near future.
For ICC, the best way is immediately to issue all the documents to me as I required. Perhaps, ICC and some ICC
employees will be safe as long as ICC would like to get an agreement with me.
Good luck!

Sincerely,
George
发件人: David Nijhawan <dnijhawan@icc‐nw.net>
发送时间: 2020年2月24日 14:59
收件人: [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected]
<[email protected]>
抄送: Jennifer Bean <jbean@icc‐inc.net>; Janica McEndollar <jmcendollar@icc‐inc.net>; Eric Raibley <eraibley@icc‐
inc.net>; John Vinti <jvinti@icc‐nw.net>; David Nijhawan <dnijhawan@icc‐nw.net>
主题: Subpoena to ICC ‐ George Zou/Bo Zou
Mr. Zou –

We received your notice of subpoena. My name is David Nijhawan, and I am general counsel at ICC. Please
communicate with me directly.

We object to the subpoena on several grounds pursuant to the Federal Rules of Civil Procedure. Moreover, as you are
aware, counsel for the adverse party in your lawsuit objects as well. If further action continues on your part, we do
intend to file a motion to quash.

The gravamen of our objections rests in FRCP 45 and its applicable provisions:

1. The request is overbroad and not narrowly tailored
2. The method of service remains flawed (we never received a paper copy)
3. The time limit for the request remains deficient
4. You violated the civil procedure rules by not notifying your adverse party through their counsel
5. Documents you request remain wholly unrelated to your lawsuit against Linde Engineering
6. Responding to this would cause undue hardship on us to produce due, primarily, to the scope
7. It would require us to produce documents over 100 miles away

Sincerely,

David



2
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EXHIBIT “1”
VP Operations
D. Close
Director Engineering Director Manufacturing Manager Procurement Manager Project Mgmt. Manager Scheduling

J
Jerry Gump Aaron Starkebaum Randy Rogers Jehna Ferster
Manager Piping Plant Manager Buyer Project Manager Project Planner

Eli McDaniel Zech Snyder Mike Hackler
Manager I, E & C Quality Manager Buyer Project Manager Production Planner

Scott Pickens Sheila Malley‐Fischer Jake Rogers
Manager Civil/Structural HSE Manager Buyer Project Manager Engineering Planner

Amol Sawant Stewart Schmitt Wade Uhrich
Manager Equipment Material Manager Buyer Project Manager Cryo

Michelle Church
Time Keeper Project Coordinator
Shop Buyer
Terri Uhl Sonya Goff Amanda Alexander
Expediting Document Control
Rachel Owens Pam McCall
2/15/16
Logistics Document Control
Rebecca Dykes Cindy Rogers
5/16/05
Dave Shaw
Material Control 7/12/94
Mandy Abell
Material Control
Tonya Williams
Linde [Zou] 002829

Confidential
Director of Engineering
Jerry Gump
Manager Piping Manager I, E & C Manager Civil/Structural Manager Equipment

Eli McDaniel Scott Pickens Amol Sawant
Piping Design IE&C Design Civil/Structural Design Equipment Design

Eric Cantos Jerry Church Nga Thi Le David DuVal
10/15/18 12/3/12 5/21/07 7/1/01
Piping Design IE&C Design Civil/Structural Design Static Equipment

Nancy Hubbard Jack Killingsworth Todd Maye Charlie Davis
1/7/19 11/10/98 12/11/06 3/7/11
Piping Design IE&C Design Civil/Structural Design Static Equipment

Cathy Potter open Roy Madewell open
1/31/05 12/1/05
Piping Design Project Controls Civil/Structural Design Rotating Equipment

Armi Torres Ron Arias Larry Palmer Kyle Hennessee
10/15/18 12/06/10 10/24/94 1/28/13
Piping Design Instruments & Control Civil/Structural Rotating Equipment

Stephanie Wade Bryant Tyler Dale MacCallum Martin Dryden
10/8/18 5/11/18 5/15/95 9/25/01
Piping Engineer Electrical Engineer Civil/Structural General Drafter
Dustin Duncan Harry Arnold Terry Ridenhour Shilah Williams
4/11/11 2/7/11 5/9/05 10/29/07
Piping Engineer Electrical Engineer Civil/Structural
Kenneth Sharp open open
6/23/14
Piping Engineer
George Zou
10/1/18
Linde [Zou] 002830

Confidential
Natural Gas - Tulsa*
CEO President
T C. Conerly
NG Executive Assistant
T A. Schlosberg
NGS Technology NGP Product Management NGY Cryogenics NGM Engineering Operations NGS Sales NGS Sales NGC Shared Services
T D. Close T G. Pollok T S. Wolff

T A. Puigbo T B. Hughes POC K. Leitch (CO-I,A,C,P,L; HR)
NGS Proposal Management NGP Product Development NGY Spare Parts NGO Engineering NGC Contract Management HR Human Resources
T C. Allen T C. Kennard POC P. Barnett T J. Gump T J. Johnson T D. Hoey
NGS Systems Engineering Instrument & Controls NGO Project Management IT-
NGY COL Contract Management IT Customer Support
Optimization RNA
T G. McCool POC F. Besser T J. Marshall HS N. Gandhi T A. Sheppard
NGS P&ID NGO Manufacturing Material Technology &

NGY Field Service AGM CAD QAC
QA/QC
T V. Addington POC A. Starkebaum
POC J. Cuevas T M. Chindaliya T C. Gillman
NGS Process Engineer

NGY Design COP Project Controls QHS QHSE
T K. Bigger
POC A. Hewitt T C. Blair T (TBD)
NGS Systems Engineering

NGY Design NGO Procurement
T J. Boulton
POC D. Holman T R. Rogers
NGS Process Engineer
T A. Mileur NGY Project Engineering
POC J. Mcbride
NGS Systems Engineering
I&E Controls
T B. Wang NGY
Optimization
POC F. Missel
NGS Proposal Management
T S. Quinton NGY Project Management
POC J. Wright
Location Code: BB=Blue Bell, BG=Bridgewater, BR=Brazil, CH=Chile, CA=Canada, HS = Holly Springs, L=Lugoff, MX=Mexico,
MH=Murray Hill, N=Naperville, POC = Port of Catoosa, SV=Stewartsville, TW=Tonawanda, T=Tulsa, W=The Woodlands *Physical Work Location
Linde [Zou] 002831

Confidential
Natural Gas – Operations*
NGO Engineering Operations
T Dave Close
NGO Engineering NGO Project Management NGO Manufacturing
T J. Gump T J. Marshall POC A. Starkebaum
NGO Equipment NGO Piping NGO I, E & C NGO Civil/Structural NGO Engineering
T K. Hennessee T E. McDaniel T S. Pickens T A. Sawant T K. Green
NGO Project Management

NGO Static Equipment NGO Piping Design NGO I, E &C Design NGO Civil/Structural Design
T M. Hacker
T C. Davis T E. Cantos T J. Church T N. Le
NGO Assistant
NGO I, E &C Design NGO Civil/Structural Design
NGO Equipment Design NGO Piping Design T J. Kupiec
T J. Killingsworth T T. Maye
T D. DuVal T D. Duncan
NGO Document Control
NGO Instrument & Controls NGO Civil/Structural
NGO Static Equipment T P. McCall
NGO Piping Design
T B. Tyler T T. Ridenhour
T J. Franklin
T N. Hubbard NGO Document Control
NGO General Drafter T C. Rogers

NGO Piping Design
T S. Williams
NGO Project Management
T C. Potter
T J. Rogers
NGO Piping Design
T K. Sharp
Location Code: BB=Blue Bell, BG=Bridgewater, BR=Brazil, CH=Chile, CA=Canada, HS = Holly Springs, L=Lugoff, MX=Mexico,
MH=Murray Hill, N=Naperville, POC = Port of Catoosa, SV=Stewartsville, TW=Tonawanda, T=Tulsa, W=The Woodlands *Physical Work Location
Linde [Zou] 002832

Confidential
EXHIBIT “”
012013434 5678ÿ
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e]fÿghijhkjkjÿllmnoÿpq
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|C:ÿ}S~WaTXÿa{\ÿ^}S~WaT_àUUS̀WbTVcdxÿT]S[SX̀ÿVWaÿpbÿ^T]S[S`_àUUS̀WbTVcd
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2020.08.20 - DOC104 - Zou (Linde) - Plaintiff's Objection To Defendant's Motion For Protective Order

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2020.08.20 - DOC104 - Zou (Linde) - Plaintiff's Objection To Defendant's Motion For Protective Order

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OKLAHOMA

PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION

1. Defendant’s motion for protective order must be denied without a certification

“RFP 2, 3, 4, 7, 36: Granted, as limited by Plaintiff. Plaintiff limited

2. Provide e-mails between Plaintiff and young engineer Kenny Sharp

3. Provide e-mails between Plaintiff and young engineer Dustin Duncan

5. Provide e-mails between Plaintiff and Kelly Leitch, from

6. Provide internal investigation reports made by Deana Hoey for Plaintiff’s

DEFENDANT’S OBJECTIONS AND RESPONSES

Plaintiff’s Second Request for Production.

/s/ Jessica L. Craft

LITTLER MENDELSON, P.C.

LITTLER MENDELSON, P.C.

ATTORNEYS FOR DEFENDANT LINDE

SENT VIA EMAIL: [email protected]; [email protected];

/s/ Jessica L. Craft

REQUEST FOR PRODUCTION NO. 1: Provide any correspondence, documents, emails,

DEFENDANT’S OBJECTIONS AND RESPONSES

Plaintiff’s Third Request for Production.

/s/ Jessica L. Craft

LITTLER MENDELSON, P.C.

LITTLER MENDELSON, P.C.

ATTORNEYS FOR DEFENDANT LINDE

/s/ Jessica L. Craft

RESPONSE: Defendant objects to Request No. 1 insofar as it requests information previously

REQUEST FOR PRODUCTION NO. 2: Provide any correspondence, documents, emails,

RESPONSE: Defendant objects to Request No. 2 insofar as it requests information previously

REQUEST FOR PRODUCTION NO. 3: In Plaintiff’s First Set of Requests of Interrogatories

RESPONSE: Defendant objects to Request No. 3 because it is misleading, confusing, and

REQUEST FOR PRODUCTION NO. 5: Provide any correspondence, emails, documents,

RESPONSE: Defendant objects to Request No. 5 insofar as it requests information previously

RESPONSE: Defendant objects to Request No. 6 insofar as it requests information previously

Defendant refers to Linde [Zou] 000029, previously produced.

RESPONSE: Defendant objects to Request No. 7 insofar as it requests information previously

RESPONSE: Defendant objects to Request No. 8 insofar as it requests information previously

DEFENDANT’S OBJECTIONS AND RESPONSES

Plaintiff’s Fourth Request for Production.

/s/ Jonathan G. Rector

LITTLER MENDELSON, P.C.

LITTLER MENDELSON, P.C.

ATTORNEYS FOR DEFENDANT LINDE

/s/ Jonathan G. Rector

incorporated by reference in response to each Request as if completely restated therein.

opinions, or legal theories of Defendant’s attorneys or other representatives of Defendant

working to assist trial preparation or in anticipation of litigation, such is protected from

discovery by the work product privilege.

subject matter or requests inquire, in whole or in part, into medical-peer-review records or

medical-committee records of Defendants’ medical peer review committee, professional review

from discovery by the Federal Rules of Evidence.

reasonable time frame and reasonable geographic area.

6. Defendant objects to Plaintiff’s requests to the extent they would require

production of documents protected by the physician-patient privilege or the Health Insurance

Portability and Accountability Act (“HIPAA”).

7. Defendant objects to Plaintiff’s interrogatories to the extent they would require

production of documents containing personal and confidential information regarding individuals

who are not parties in this lawsuit.

8. Defendant objects to Plaintiff’s interrogatories to the extent they seek production

of confidential, financial, or proprietary documents about employees, clients, or business

and facts and this lawsuit.

by the Federal Rules of Civil Procedure.

those documents are not in the Defendants’ possession, custody, or control.

REQUESTS FOR PRODUCTION

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