JUDGMENT CREDITOR/PLAINTIFF’S DEMANDS FOR PRODUCTION PROPOUNDED TO JUDGMENTDEBTOR/ DEFENDANT – SET NO. 1
agents, insurers, independent contractors, representatives, successors, assigns or others,and not merely information known by Debtor or of Debtor’s own knowledge.
1. “WRITINGS” means:a. All written, typed, or other graphic materials of any kind or nature, and any othertangible thing by which information or data is stored, including, without limitation, any writingsas defined by Evidence Code section 250, including any originals as defined by EvidenceCode section 255, and any duplicates as defined by Evidence Code section 260, any drawing,film, graph, chart, photograph, phone record, mechanical or electrical sound recording, ortranscript thereof, any retrievable data, whether in computer storage, carded, punched, taped,coded or stored electronically, electrostatically, electromagnetically, or otherwise, and anyother data compilation from which information can be obtained (including, without limitation, allemails and attachments thereto).b. All agreements, draft agreements, calendars, calendar appointment logs, telephonemessages, telephone logs, forms, facsimile transmissions, cancelled checks, bankstatements, financial statements, loan applications, leases, diaries, worksheets, abstracts,summaries, notes, jottings, audits, charts, diagrams, newspapers, expense reports,appraisals, rent rolls, income tax returns, title reports, inspection reports, tax notices,privileged communication logs, papers, books, communications, emails, letters, reports,proposals, letters of intent, commitment letters, loan applications, correspondence,memoranda, telegrams, cables, notations, work papers, draft documents, statements,opinions, studies, affidavits, declarations, analyses, evaluations, transcripts, minutes,recordings, tapes, photographs, slides, films, and any other sound or visual recordings on anymedia, contracts, instructions, charts, manuals, brochures, publications, schedules, computerprintouts, microfilm, books of account, journals, ledgers, records, and all things similar to anyof the foregoing however denominated, including all partial and complete copies, drafts andfinal versions thereof, and attachments and enclosures therewith.c. All materials as described above within the possession, custody or control of