“Communication(s)” means the transmittal of information by any means andincludes communication of any kind, whether written, oral, electronic or other.13.
“Documents” includes every writing, recording, or record in any form, whetherhandwritten, printed, typed, taped, or in any other graphic, digital, magnetic, optical, ormechanical form, however produced, reproduced, or recorded, and should be construed to besynonymous in meaning and scope to the usage of this term in Federal Rule of Civil Procedure34(a). The term includes, without limitation, all memoranda, reports, data, correspondence, blogpostings, phone messages, diaries, logs, notes, bills, invoices, checks, receipts, and e-mailmessages, including those within the personal or private possession, custody, or control of MP3tunes. The term also includes, without limitation, any data compilations from whichinformation can be obtained, and if necessary, translated into usable form through the use of anymachine, device, or equipment, whether or not sent, received, or otherwise transmitted. The termalso includes, with limitation, every draft of a document, and any copy that is not identical ineach and every respect to the original or another copy.14.
Each of the following interrogatories is continuing in nature, and EMI herebyrequests that if you obtain any additional responsive information or documents at any later date,you promptly so inform EMI and submit supplemental or amended answers and documents.15.
Any interrogatory relating to any communications or meetings with a corporation,partnership, or other business or governmental entity shall include any communications ormeetings with its officers, directors, controlling shareholders, employees, representatives, agents,and attorneys acting on the entity’s behalf.16.
If you believe that any of the information requested by the followinginterrogatories calls for assertions of a claim of privilege, answer so much of the interrogatory asis not objected to, and set forth with respect to each specific item of information as to which aclaim of privilege is asserted the nature of the privilege asserted (e.g., attorney-client or work product) and the basis for your claim. For each item of information as to which you claimprivilege, provide a privilege log.17.
If you are unable to answer in interrogatory in full or in part, you should answer itto the extent possible, and state an explanation as to why the remainder cannot be answered and astatement as to the nature of the information or knowledge that cannot be furnished. If you knowthe name of an individual or entity possessing any or all of the information sought by the