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books, pamphlets, periodicals, agreements, contracts, memoranda,
<br /> correspondence, telegrams, studies, minutes, notices, reports,
<br /> records, handwritten notes, working papers, lists, charts,
<br /> graphs, indices, maps, tape recordings, discs, video tape record-
<br /> ings, other electronic recordings, data sheets, computer data,
<br /> and data processing cards .
<br /> B. Identify. The term "identify" as used herein means :
<br /> (1) In the case of a person, (a) the full name of the per-
<br /> son; (b) the present or last known home and business addresses
<br /> and telephone numbers of the person; (c) the present or last
<br /> known business or employment title, office, and/or position held
<br /> by the person; and (d) when an interrogatory refers to past
<br /> activities, the business or employment affiliation and title,
<br /> office, or position of the person during the time period referred
<br /> to in the interrogatory.
<br /> (2) In the case of a document, (a) a general description of
<br /> the document (eq. , letter, memorandum, handwritten note, report,
<br /> etc. ) ; (b) the date the document was prepared; (c) the identity
<br /> of each person who prepared, signed, sent, or originated the
<br /> document; (d) the identity of each addressee and distributee; (e)
<br /> a brief description of its contents; and (f) the identity of the
<br /> last known or present custodian of the original or, if such
<br /> custodian is unknown, the last known or present custodian of a
<br /> copy. If a document to be identified was at any time in your
<br /> possession, custody, or control, and has been destroyed or
<br /> otherwise disposed of, state all of the information requested
<br /> above; state the date of destruction or other disposition;
<br /> identify the person or persons who directed or authorized the
<br /> destruction or disposition; identify the person or persons who
<br /> actually destroyed or disposed of the document; and explain with
<br /> particularity the reasons for such disposition.
<br /> (3) In the case of a meeting, (a) the date and approximate
<br /> time when the meeting took place; (b) the place where the meeting
<br /> was held; (c) the purpose of the meeting and/or the reason why
<br /> the meeting was called; (d) the identity of each person who
<br /> chaired or presided over the meeting; (e) the identity of each
<br /> person who attended the meeting; (f) the approximate duration of
<br /> the meeting; and (g) a brief description of the topics discussed
<br /> at the meeting.
<br /> C. Unavailable or unknown information. If the information
<br /> requested in an interrogatory is not available or is unknown,
<br /> state the efforts that were made to obtain the information and,
<br /> if known, identify the source from which the information might be
<br /> obtained.
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