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Plaintiff Second Request for Production of Documents

Plaintiff Second Request for Production of Documents

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Published by: orionav6402 on Sep 01, 2011
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09/01/2011

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
CASE NO.11-20120-CIV-SEITZ/SIMONTONTRAIAN BUJDUVEANUPlaintiff,vs.DISMAS CHARITIES,INC.,ANA GISPERT,DEREK THOMAS,LASHANDA ADAMSDefendants. _________________________________________/
PLAINTIFF'S SECOND REQUEST FOR PRODUCTIONOF DOCUMENTS AND ELECTRONICALLY STORED INFORMATIONSTO DEFENDANTS DISMAS CHARITIES,INC.,ANA GISPERT,DEREK THOMAS AND LASHANDA ADAMS.
Plaintiffs, Traian Bujduveanu, pursuant to Rule 34 of the Federal Rules of CivilProcedure, hereby request that Defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas and Lashanda Adams produce the originals of documents described belowwithin thirty (30) days of service of this notice to be at the address as set forth in theFirst Amended Complaint or at such other time and location as the parties maymutually agree.
DEFINITIONS
For purposes of this Request for Production of Documents, the following definitionsshall apply unless otherwise specifically indicated:A. The word "document" shall mean any written or graphic matter or other meansof preserving thought or expression, and all tangible things from which informationcan be processed or transcribed, including, but not limited to, correspondence,memoranda, notes, messages, letters, telegrams, teletyped messages, bulletins, diaries,chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets,receipts, computer printouts, schedules, affidavits, contracts, transcripts, surveys,graphic representations of any kind, photographs, graphs, microfilm, video tapes, taperecordings, motion pictures or other film.B. All documents produced shall be in both hard copy format and electronic media,to the extent the documents exist in electronic media. If the documents once existed in1
 
electronic media but were deleted, Defendants shall produce mirror image copies of the electronic media from which the documents were deleted or shall produce theelectronic media.C. "Mirror image copies" means true and exact copies of the electronic mediaincluding the portion of the electronic media from which material has been deleted.D. "All documents and electronic media relating to" means any and all documents or communications that constitute, comprise, contain, embody, reflect, identify, state,refer directly or indirectly to or are in any way relevant to the particular subject matter identified in the request.E. If any Request is deemed by Defendants to call for the production of documentscovered by the attorney/client or work product privilege, and Defendants withholdsaid documents on the basis of one or both of the privileges, provide a description of the document and the grounds for withholding the document.F. If any documents responsive to these requests have been destroyed, describe saiddocuments and the reasons for their destruction and state the date on which saiddocuments were destroyed. If any such destroyed documents existed in electronicmedia, provide the electronic media from which the documents were destroyed.G. "Person" means any natural person; public or private corporation, whether organized for profit ; governmental entity ; partnership; association; cooperative; jointventure; sole proprietorship ; or other legal entity . With respect to a business entity,the term "person" includes any natural person acting formally or informally as anemployee, officer, agent, attorney, or other representative of the business entity.H. "Policy" means each rule, procedure, or directive, formal or informal, and eachcommon understanding or course of conduct that was recognized as such by Your  present or former officers, directors, employees, agents, or other Persons acting or  purporting to act on Your behalf, that was in effect at any time during the periodcovered by these requests and includes any changes of policy.I. The terms "and" and "or" shall be construed either disjunctively or conjunctively asnecessary to bring within the scope of the discovery request all responses that mightotherwise be construed outside of its scope.J. The use of the singular form of any word includes the plural and vice versa. Inaddition, the use of any tense of any verb includes all other tenses of the verb.K. "And" and "or" shall be construed disjunctively or conjunctively as necessary inorder to bring within the scope of each request all documents which might otherwise be construed to be outside its scope.2
 
L. The term "and/or" is to be read in both the conjunctive and disjunctive and shallserve as a request for information which would be responsive under a conjunctivereading in addition to all information which would be responsive under a disjunctivereading.M. "Each" includes both "each" and "every." N. The singular and masculine gender shall, respectively, include the plural andfeminine gender, and vice versa.O. "You" and "your" shall mean yourself and all other persons acting or purportingto act on your behalf.P. "Relating to" and "relates to" mean, without limitation, relating to, concerning,constituting, mentioning, referring to, describing, summarizing, evidencing, listing,relevant to, demonstrating, tending to prove or disprove, or explain.R. "Communication" or "communications" includes, without limitation, in-personor telephone conversations, facsimiles, letters, electronic mail, telegrams, telexes,tapes or other sound recordings, or other means of transmitting information from onesource to another.S. "Plaintiffs"- The term "Plaintiffs" refers to Traian Bujduveanu, as described inthe Complaint.T. "Defendants" - The term "Defendants" in the context of this case refers to DismasCharities,Inc.,Ana Gispert,Derek Thomas,lashanda Adams.
SCHEDULE OF DOCUMENTS
1. Any and all records, correspondence, notes, communications and other documentssigned by Carlos Rodriguez, Director CCM, or any Decision Making party or individual from CCM Miami,regarding the fact that Plaintiff’s Community Custodyshould be terminated, and requirement for removal by, US Marshal Agents, fromDismas Charities and transported to FDC Miami. Provide copiy of the Return to theinstitution Order.2. Any and all records, correspondence, notes, communications and other documentssigned by USPO Steven Aasterud or any Decision Making party or individual fromUSPO, regarding the fact that Plaintiff ‘s Community Custody should be terminated,and requirement for removal, by US Marshal Agents, from Dismas Charities andtransported to FDC Miami. Provide copy of the Return to the Institutin Order.3

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