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or "documents" includes, without limitation, any preliminary, revised, superseded, or otherwise
<br />replaced draft or form of any document. The term "document" or "documents" includes, without
<br />limitation, all enclosures, attachments, and related material attached to or referenced in any
<br />document as defined above.
<br />2. "Identity," "identify," and "identification," when used with respect to a document,
<br />is a request for the following information:
<br />a. the subject of the document;
<br />b. the title of the document;
<br />C. the type of document (e.g., letter, memorandum, telegram, chart);
<br />d. the date of the document, or if the specific date thereof is unknown, the
<br />month and year or other best approximation of such date;
<br />e. the identity of the person or persons who wrote, contributed to, prepared, and
<br />originated such document;
<br />f. the identity of such person or persons to whom the document was directed or
<br />who received or reviewed the document or copies of the document or any
<br />portion thereof;
<br />g. the present or last known location and custodian of the document and the
<br />address and phone number of each custodian; and
<br />h. if the document was, but is no longer, in your possession, custody or control,
<br />or in existence, state the date and manner of its disposition.
<br />3. "Identify," when applied to anything other than a person or document means to
<br />describe its nature, location and the person who has custody of it.
<br />4. "Pertain(ing) to," "relate(d) to," or "in connection with" means, in addition to its
<br />common meaning, "connect," "support," "evidence," "discuss," "mention," "reref," "contradict,"
<br />or compromise. Anything germane, relevant, pertinent, or material is "in connection with," "relates
<br />to" and "pertains to" the subject matter referred to.
<br />5. "And" includes "and," "or," as well as "and /or," as the context requires, so as to be
<br />more inclusive of information.
<br />C:\ DATA \Pifher\HOMESTAK \OOCW281\First Interrogs.wpd 2
<br />January 29, 2002 (3:15 pm)
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