(d) The date on which the document was created;(e) The names and addresses of all persons who have had access to the documentfrom the time of its creation to the present;(f) The date on which the document was created; and(g) The name and address of the present custodian of the document, and the namesand addresses of all persons who have received copies, summaries, or explanations of the document.11. In the event that any document to which you refer in your answers to theseInterrogatories has been destroyed or discharged, or has otherwise left your possession, custody and control, set forth:(a) A general description of the document including its size, length, form and subjectmatter;(f) The date, manner, and reason(s) for destruction or discard; and(g) The names and addresses of persons authorizing and carrying out the destructionor discard of the document.12. These interrogatories are addressed to all Defendants in this case.
1. The word "documents" is used in these Interrogatories in the broad and liberalsense and means written, typed, printed, recorded or graphic matter, however stored, produced or reproduced, of any kind and description and whether an original, master,duplicate or copy, including, but not limited to, papers, notes, accounts, books,advertisements, letters, memoranda, notes of conversations, contracts, agreements,drawings, telegrams, electronic mail, tape recordings, communications, includinginter-office and intra-office memoranda, reports, studies, working papers, corporaterecords, minutes of meetings, notebooks, bank deposit slips, bank checks, cancelledchecks, diaries, diary entries, appointment books, desk calendars, photographs,transcriptions or sound recordings of any type of personal or telephone conversationsor negotiations, meetings or conferences or things similar to any of the foregoing, andto include any data, information or statistics contained within any data storagemodules, tapes, discs, diskettes, or other memory device, or other informationretrievable from any storage systems, including, but not limited to, computer-3