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