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JAN;22-x010, 09:46 From:LSNET 2093830311 To:94e1450 Pase:7,'10 <br /> 12. "And"and"or" have both conjunctive and disjunctive meanings;"all"and <br /> "any"means both"each"and"every"; the plural shall include the singular and vice <br /> versa. <br /> 13. All documents that you produce shall be organized and produced pursuant <br /> to Rule 45 of the Federal Rules of Civil Procedure. _ = <br /> 14. You are required to identify and produce all documents that are available <br /> to you, including information in the possession of your present and former attorneys and <br /> investigators, and including investigators for your attorneys, employees, representatives, <br /> consultants,agents;or other persons acting on your behalf, and not merely documents or <br /> things of your personal knowledge. <br /> 15. If you are unable to comply with a demand for any document in full, you <br /> are requested to specify, pursuant to Federal Rule of Civil Procedure 45, whether your <br /> inability to comply is becaus., the document has never existed, has been destroyed, has <br /> been lost,misplaced or stolen,and/or has never been, or is no longer in your possession, <br /> custody or control. The statement shall set forth the name and address of any person or <br /> organization known or believed by you to have possession,custody or control of the <br /> document. _. <br /> 16. If your response to any part of these requests for production is,that you <br /> lack knowledge regarding the information sought or the documents to be identified, <br /> describe all efforts made by you to obtain the information or documents necessary to <br /> furnish a response. <br /> - 3 . <br />