within thirty days of receipt of service shall be deemed a confession that thedocument does not exist.You are further requested pursuant to O.C.G.A. § 24-10-26 to produce thesedocuments at any deposition, mediation session, hearing or trial in this case.DEFINITIONSThe following definitions are to be used in responding to the following requests.A. “Plaintiff,” means MIDLAND FUNDING LLC, ASSIGNEE OF CHASEBANK(USA), N.A., or any agent, employee, officer, director, or any other personacting on its behalf.B. “Defendant” means, JILL SHERIDAN an individual.C. “Document” means any written, recorded or graphic matter, whetherproduced, reproduced or stored on papers, cards, tapes, belts, or computer devicesor any other medium in your possession, custody or control, or known by you toexist, and includes originals, all copies of originals, and all prior drafts. It includesall original business records, non-identical copies, computations, memoranda of oral or telephone conversations, tabulations, records of correspondence, notesmade on other documents, microfilms, etc.