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record, drawing, plan, sketch, graph, index, list, tape,
<br /> photograph, microfilm, data sheet or data processing card, or any
<br /> other written, recorded, transcribed, punched, taped, filmed or
<br /> graphic matter, however produced or reproduced which is in your
<br /> possession, custody or control or which was, but is no longer, in
<br /> your possession, custody or control .
<br /> 4 . Identification. As used herein, the terms
<br /> "identification, " "identify, " or "identity, " when used in
<br /> reference to (a) a natural individual, require you to state his or
<br /> her full name and residential and business address and telephone
<br /> number; (b) a corporation, require you to state its full corporate
<br /> name and the address of its principal place of business and the
<br /> name of its chief executive officer; (c) a business, require you
<br /> to state the full name or style under which the business is
<br /> conducted, its business address and the identity of the persons
<br /> who own, operate, and control the business; (d) a document,
<br /> require you to state the number of pages and the nature of the
<br /> document (e .g. , letter or memorandum) , its title, its date, its
<br /> substance, the names of its authors and recipients and its present
<br /> location and custodian; (e) a communication, require you, if any
<br /> parts of the communication was written, to identify the documents
<br /> which refer to or evidence the communication, and, to the extent
<br /> that the communication was non-written, to identify the persons
<br /> participating in the communication and to state the date, manner,
<br /> place and substance of the communication.
<br /> 5 . Person. As used herein, the term "person" means any
<br /> natural individual in any capacity whatsoever or any entity or
<br /> organization, including divisions, departments and other units
<br /> therein, and shall include, but not be limited to, a public or
<br /> private corporation, partnership, joint venture, voluntary or
<br /> unincorporated association, organization, proprietorship, trust,
<br /> estate, governmental agency, commission, bureau or department .
<br /> 6 . Representative. As used herein, the term
<br /> "representative" means any and all agents, employees, servants,
<br /> officers, directors, attorneys, investigators, partners,
<br /> accountants, or other persons acting or purporting to act on
<br /> behalf of plaintiff.
<br /> 7 . Resources . As used herein, the term "Resources" means
<br /> Mid-Continent Resources, Inc.
<br /> 8 . State the basis . As used herein, the term "state the
<br /> basis" requires you to describe in detail each and every fact and
<br /> circumstance upon which you rely in support of your contention.
<br /> 9 . You. As used herein, the terms "you, " "your" or
<br /> "yourself" refer to the Division and each of its representatives .
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