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<br />books, papers, magazines, newspaper articles, logs, calendars, diaries,
<br />journals, lists, brochures, pamphlets, literature, advertising, computations,
<br />tabulations, computer printouts, bills, statements, invoices, vouchers, bills
<br />of lading, schedules, purchase orders, contracts, agreements, books of
<br />original entry, accounts, checks, tape recordings, photostats, motion
<br />pictures, slides, photographs, sketches, drawings, charts, graphs, video
<br />recordings, transcripts and other similar objects, or any other written,
<br />printed, recorded, or video matter or tangible thing on which any words or
<br />phrases are affixed or conveyed:
<br />
<br />b. Copies of such documents upon which appear any initialing, notation or
<br />handwriting of any kind not appearing on the original;
<br />
<br />c. Such documents, whether they were prepared by you, or your agents,
<br />employees, consultants, representatives or attorneys, for their own use,
<br />your use, or for transmittal in any manner, or were received by any means
<br />by you;
<br />
<br />d. Such documents, wherever located, whether in the files of any agent,
<br />employee, consultant, representative, or attorney of your, or in any file in
<br />the possession or direction or control. bfyou.
<br />
<br />4. Wherever in these document requests you are asked to identify a document, you
<br />shall designate the type of document (i.e., letter, inter-office memorandum, report, etc.) and shall
<br />state:
<br />
<br />a. Information sufficient to enable identification of the document, including
<br />its date, the name of the addressees, the name of the signer or signers,
<br />author(s), the title or heading of the document, or other appropriate
<br />identifying information;
<br />
<br />b. The identity of the persons to whom the original and all copies were sent;
<br />and
<br />
<br />.~ ,
<br />
<br />c. The present or last known location or possessor of the original of the
<br />document and of each copy thereof.
<br />
<br />5. Whenever in these document requests you are asked to identify or produce a
<br />document which is deemed by you to be properly withheld from production for inspection or
<br />copying on the ground of privilege, you shall provide a listing by title or subject heading, date,
<br />author, addressee, and person copied is nevertheless required, including a statement of the
<br />statutory privilege asserted.
<br />
<br />6. The singular form of a word, e.g., document or person, shall refer to the plural as
<br />well, and words used in the masculine gender also include the feminine.
<br />
<br />7. Unless otherwise indicated, "statement" as used herein refers to a written
<br />statement signed or otherwise adopted or approved by the person making it; or a stenographic,
<br />
<br />92674788vl 809449
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