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0 ! <br /> 13. "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 /> 14. All documents that you produce shall be organized and produced pursuant <br /> to Rule 45 of the Federal Rules of Civil Procedure. <br /> 15. 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 /> 16. 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 because 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 /> 17. 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 /> ()IiS Nest2607T2234.I j <br />