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CLECO GENERATION SERVICES, LLC; CLECO TRADING &
MARKETING, LLC; CLECO CORPORATION; and CLECO POWER, LLC
Through its agent for service of process,
2030 Donahue Ferry Road
CLECO MIDSTREAM RESOURCES, LLC; CLECO GENERATION SERVICES, LLC; CLECO TRADING & MARKETING, LLC; CLECO CORPORATION; and CLECO POWER, LLCis required, pursuant to this Notice of Deposition and the subpoena duces tecum issued
herewith, to produce at JOHNSON, SIEBENEICHER & INGRAM, 2757 Highway 28 East, Pineville, LA 71360, to inspect and copy on or before September 17, 2010, all documents set forth in Exhibit A in the possession, custody or control of CLECO or its agents, representatives, assigns or successors.
NO ORAL TESTIMONY IS REQUIRED IF PRODUCTION IS MADE PRIOR TO THE SCHEDULED DEPOSITION BY MAILING A CERTIFIED COPY OF THE RECORDS TO JAMES H. GIBSON, ALLEN & GOOCH, P. O. BOX 81129, LAFAYETTE, LA 70598-1129.
MICHAEL T. JOHNSON #14401
S. AARON SIEBENEICHER #23301
2757 Highway 28 East
P.O. Box 648
Alexandria, La. 71309
Business Phone: (318) 484-3911
Business Fax: (318) 484-3585
JAMES H. GIBSON #14285
DAVID J. AYO #28868
2000 Kaliste Saloom Rd Suite 400
For purposes of this written discovery the list of definitions below shall apply to be used by the person responding to these requests for production of documents.
"Communication" is a transmission from one person to another or in the presence of another, whether written or oral, telephonic, electronic, or by any other means.
“Defendant(s)” shall mean THE CITY OF ALEXANDRIA, LOUISIANA. "Describe" or "specify" means the following unless additional information is requested in a given interrogatory:
As used herein, the terms "document" and "documents" shall be used in their broadest sense and shall mean and include all written, printed, typed, recorded, electronic or graphic matter of every kind and nature, whether an original or a copy, including all attachments and appendices thereto.
Without limiting the foregoing, the terms "document" and "documents" shall include all agreements, contracts (meaning the written reflection of terms of an agreement), communications, correspondence, business or other plans, letters, hand or typewritten notes, telegrams, telexes, messages, memoranda, reports, books, summaries or other records of meetings, conferences or interviews (whether the same was in person, by telephone, by electronic means, or otherwise), summaries or other records of personal conversations (whether in person, by telephone, by electronic means, or otherwise), minutes or summaries of other records of
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