motion to compel - White Collar Fraud

printing, photostating, photographing, and every other means of recording upon any
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tangible thing any form of communication or representation, including letters, words,
pictures, sounds, or symbols, or combinations thereof. Any such document bearing on
any portion thereof any mark (including but not limited to initials, stamped indicia,
comments, or notations of any character) not a pan of the original text or photographic
reproduction thereof, is to be considered to be a separate document.
10. "EMPLOYEE" refers to any natural person employed by YOU during the time
specified in the interrogatory.
11. "FORMER EMPLOYEE" refers to any natural person who was once employed by
YOU during the time specified in the interrogatory, but is not presently employed by
YOU.
12. "FULFILLMENT PARTNER" refers to any retailer, manufacturer, distributor,
cataloguer, merchant, vendor, or other broker or seller of goods, other than YOU, whose
goods are offered for sale on, through, or via YOUR SITE (said goods are referred to
herein^as PARTNER PRODUCTS).
13. "IDENTIFY" when referring to a PERSON requires YOU to provide the (a) name of
the PERSON; (b) the last known ADDRESS of the PERSON; (c) the last known
telephone number of the PERSON; and (d) the relationship, if any, of the PERSON to
YOU.
14. "IDENTIFY" when referring to an event, incident, occasion, or occurrence requires
YOU to provide the date and location of that event, incident, occasion, or occurrence.
15. "IDENTIFY" when referring to a DOCUMENT requires YOU to (a) IDENTIFY the
PERSON who created the document; (b) state the date on which the DOCUMENT was
created; and (c) identify the present location of that DOCUMENT. If that document is
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PLAINTIFF'S FIRST SET OF INTERROGATORIES DIRECTED TO DEFENDANT OVERSTOCK.COM, INC.