Document oe7N5GoQqezGmbZkNNdNaxm3g

C 051010220 1 offers, notations of any sort of conversations, telephone calls, 2 meetings or other communications, bulletins, magazines, 3 publications, printed matter, photographs, microfilms, indexes, 4 computer printouts, teletypes, telefax, invoices, worksheets and 5 all drafts, alterations, modifications, changes and amendments of 6 any of the foregoing, tapes, tape recording transcripts, graphic or 7 aural records or representations of any kind, and electronic, 6 mechanical or electric records of representations of any kind, of 9 which you have knowledge or which are now, or were formerly in your 10 actual or constructive possession, custody or control, or which 11 come into your control during the course of this litigation. 12 4. "Possession, custody or control" includes the joint 13 or several possession, custody or control not only by the person to 14 whom these interrogatories and requests are addressed, but also the 15 joint or several possession, custody or control by each other 16 person acting or purporting to act on behalf of the person, whether 17 as employee, attorney, accountant, agent, sponsor, spokesman or 18 otherwise. 19 5. "Relates to" means supports, evidences, describes, 20 mentions, refers to, contradicts or comprises. 21 6. "Person" means any natural person, firm, corporation, 22 partnership, proprietorship, joint venture, organization, group of 23 natural persons or other association separately identifiable, 24 whether or not such association has a separate juristic existence PLAINTIFF'S FIRST INTERROGS, ETC. 3