United Western Bancorp Inc (fka UWBKQ)

[Deadmau5]

11/23/2011 NEW FILING -- REPLY MEMORANDUM IN SUPPORT OF PLAINTIFF’S RENEWED SECOND MOTION TO COMPEL PRODUCTION OF THE COMPLETE ADMINISTRATIVE RECORD

OTS/FDIC could be in trouble. UWBK not backing down.

http://www.scribd.com/doc/73633164/UWBK-11-23-2011

I. Defendants’ Discovery Responses Contradict Their Certifications That The
Administrative Record Is Complete.

II. Defendants’ Evasive And Narrow Discovery Responses Are Inadequate.

III. Defendants Claim of Privilege Has No Legal Basis.

IV. The Bank’s Requested Relief Is An Appropriate And Limited Remedy To
Defendants’ Inadequate Compilation of the Record.

V. Conclusion
In sum, the Bank asks that the Court grant its renewed second motion to compel
production of the complete administrative record including complete discovery responses and for
the requested deposition to verify the same. The Bank also requests a hearing to conclusively
resolve this issue.