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Doc 273-1-Instructions and Definition for Production of Documents and Depositions

Doc 273-1-Instructions and Definition for Production of Documents and Depositions

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Published by Dentist The Menace
Doc 273 - 1
Filed April 17, 2012
Doc 273 - 1
Filed April 17, 2012

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Published by: Dentist The Menace on May 23, 2012
Copyright:Attribution Non-commercial


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The documents covered by this request include all documents in your possession,custody or control, including but not limited to documents that may be in the possession of youragents or managers.2.
Each request for the production of documents shall be deemed continuing innature. If at any time additional documents come into your possession, custody or control or arebrought to your attention, prompt supplementation of your response to these requests is required.3.
Please produce documents in the same form and same order as they are kept in theordinary course of business, or otherwise organize and label them to correspond with thecategories of these requests. A request for a document shall be deemed to include a request forany and all file folders, bindings, or other containers in which the document was maintained.The titles, labels, or other descriptions on the boxes, file folders, bindings, or other containers areto be left intact. Documents from any single file should be produced in the same order as theywere found in such file. If copies of documents are produced, such copies should be legible andbound or stapled in the same manner as the original. Documents attached to each other shouldnot be separated.4.
If and to the extent documents are maintained in a database or other electronicformat, you shall produce along with the document(s) software that will enable access to theelectronic document(s) or database(s) as you would access such electronic document(s) ordatabase(s) in the ordinary course of your business.
Case 3:12-bk-01573 Doc 273-1 Filed 04/17/12 Entered 04/17/12 16:43:35 DescExhibit Ex. A to Rule 2004 Motion Page 1 of 4
Documents shall be produced in such a fashion as to identify the department,branch, or office in which they were located and, where applicable, the natural person in whosepossession it was found a
nd the business address of each document’s custodian.
If you object to any portion of a request, please provide all documents and thingsrequested by any portion of the request to which you do not object and specifically identify therespect in which the request is objectionable.7.
If, in responding to these requests, you encounter any ambiguities whenconstruing a request or definition, the response shall set forth the matter deemed ambiguous andthe construction used in responding.8.
Any document withheld from production based on privilege or any similar claimshall be identified by: (1) the type of document, (2) the general subject matter of the document,(3) the date of the document, and (4) such other information as is sufficient to identify thedocument, including the author(s) of the document, the addressee(s) of the document, anyrecipient of the document, whether or not identified on the face of the document, and, where notapparent, the relationship of the author(s) and the addressee(s) to each other. The nature of eachclaim of privilege shall be set forth.9.
When a document contains both privileged and non-privileged material, the non-privileged material must be disclosed to the fullest extent possible without thereby disclosing theprivileged material. If a privilege is asserted with regard to part of the material contained in thedocument, you must clearly indicate the portions as to which the privilege is claimed. When adocument has been redacted or altered in any fashion, identify as to each document the reasonfor the redaction or alteration, the date of the redaction or alteration, and the person performingthe redaction or alteration. Any redaction must be clearly visible on the redacted document.
Case 3:12-bk-01573 Doc 273-1 Filed 04/17/12 Entered 04/17/12 16:43:35 DescExhibit Ex. A to Rule 2004 Motion Page 2 of 4
Documents not otherwise responsive to this request shall be produced if suchdocuments mention, discuss, refer to or explain the documents which are called for by theserequests.11.
The use of the singular form of any word includes the plural and vice versa. Thepast tense shall include the present tense and vice versa.12. The word
“document” includes, without limitation, electronic and
computerizeddata compilations.
1. All documents relating to the insurance coverage dispute with National Union(the "Coverage Dispute"), including without limitation, the document production by the partiesin National Union Fire Insurance Company of Pittsburgh, Pa. v. Small Smiles Holding Co., LLC,Civil Action No. 3:10-cv-00743, U. S. District Court for the Middle District of Tennessee (the"National Union Case").The Committee requests that it receive copy of the identical production as made in theNational Union Case, including in the same format, OCR'd, and with the following fields of metadata: (1) bates ranges (2) family associations (3) document address information (4) documentauthor (5) document title or subject (6) document dates (including creation, modification andsent dates) (7) custodian and (8) for non-redacted documents, text searchable files on the
document’s content.
 2. Un-redacted copies of all pleadings and other documents filed or served in theNational Union Case.3. All agreements regarding the Coverage Dispute.
Case 3:12-bk-01573 Doc 273-1 Filed 04/17/12 Entered 04/17/12 16:43:35 DescExhibit Ex. A to Rule 2004 Motion Page 3 of 4

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