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7. If information responsive to a request is not in the Company's possession, custody, or control,
<br /> identify the persons or entities from whom such information may be obtained. For each individual
<br /> or entity that possesses responsive information,please provide the following`. name, last known or
<br /> current address, telephone number, and affiliation with the Company or the Facility.
<br /> 8. If you believe there are grounds for withholding information or documents that are responsive to
<br /> this request, e.g., attorney-client privilege, you must identify the information or documents and state
<br /> the basis for withholding.
<br /> DEFINITIONS
<br /> The following definitions apply to the following terms (words or phrases) as they appear in this
<br /> Information Request. Defined terms are enclosed in quotation marks:
<br /> 1. "You" or the "Company" shall mean the Thatcher Company, or its officers, managers,
<br /> employees, contractors, trustees, partners, successors, assigns, and agents.
<br /> 2. "Facility" means all buildings, equipment, structures, installations, pipes, or stationary items
<br /> owned, leased, or operated by the Company, at the property or properties located at:
<br /> 1010 Industrial Drive in Stockton, California or contiguous or adjacent to that address.
<br /> 3. As used here, "document" and "documents" shall include writings of any kind, formal or
<br /> informal, whether or not wholly or partially in handwriting (included by the way of illustration and
<br /> not by way of limitation), any invoice, receipt, endorsement, check, bank draft, canceled check,
<br /> deposit slip, withdrawal slip, order, correspondence, record book, minutes, memoranda of telephone
<br /> and other conversations (including meetings, agreements and the like), diary, calendar, desk pad,
<br /> scrap book, notebook,bulletin, circular, form, pamphlet, statement,journal, postcard, letter,
<br /> telegram, telex, report,notice,message, analysis, comparison, graph, chart, interoffice or intra
<br /> office communications, photo-stat or other copy of any documents, microfilm or other film record,
<br /> any photograph,sound recording on any type of device, any disc or other type of memory generally
<br /> associated with computers and data processing (together with the programming instructions and
<br /> other written material necessary to use such disc other type of memory). The terms "document" and
<br /> "documents" include (a) every copy of each document that is not an exact duplicate of a document
<br /> which is produced, (b) every copy that has any writing, figure or notation, annotation or the like, (c)
<br /> drafts, (d) attachments to or enclosures with any documents and (e) every document referred to in
<br /> any other document.
<br /> 4. All terms not defined herein shall have their ordinary meaning,unless such terms are defined in
<br /> the Clean Air Act or its implementing regulations at 40 CFR Part 68, in which case the statutory or
<br /> regulatory definitions shall apply.
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