IN THE UNITES STATES DISTRICT COURT FOR THE EASTERN ...

agents by reason of inquiry, including inquiry of their representatives. If you are unable to
respond to any of the following requests completely, respond to the extent possible, specifically,
and state whatever information or knowledge you have concerning the document or information
sought.
If you rely upon the attorney-client privilege or any other privilege as a ground for
objection to production of any document called for in these requests, please state for each such
document which you refuse to produce:
(a)
(b)
the name and address of the author of the document;
the name and address of any person to whom the document was sent or to whom
copies were sent or circulated at any time;
(c)
(d)
(e)
the name of any person currently possessing the document or a copy thereof;
a brief description of the nature and subject matter of the document; and
the nature of the privilege claimed.
DEFINITIONS
In an effort to avoid cumbersome and needless repetition, the Plaintiff sets forth below
certain definitions of terms. Please note that these terms are underlined in the requests that
follow in order to bring clearly to the attention of the responding party the information that is
being sought.
A. The words "you" and "your" as used herein and in the following requests include your
subsidiaries and predecessors in business as well as officers, directors, agents, servants, and
employees or any other persons, firms or corporations who acted for you or on behalf of you, or
any subsidiary or predecessor.
2