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ATTACHMENT
<br />The following definitions pertain to all of the following requests.
<br />1. For the purposes of this entire set of document requests, "DOCUMENT" or
<br />"DOCUMENTS" means a writing(s), as defined in Evidence Code § 250, and includes any
<br />written, graphic or recorded matter and any object or tangible thing of every kind, character or
<br />description, or any other means of preserving thought or expression, or any combination thereof;
<br />whether draft, revision or final; however stored, retrieved, produced, transferred, processed,
<br />reproduced or reproducible; whether printed, typed, written, produced by hand, photographed, or
<br />produced by any other process, including, but not limited to, chemical, mechanical or electronic
<br />processes; including originals and non -identical copies, whether different from the originals by
<br />reason of any notations, handwritten or blind notes, comments, underlinings, highlightings, or
<br />other distinguishing characteristics made on such copies or otherwise; in your possession,
<br />custody or control (including, without limitation, documents within the possession, custody or
<br />control of your attorneys, accountants or agents, documents that you have a legal right to obtain,
<br />documents that you have a right to copy or have access to, and documents that you have placed
<br />in the temporary possession, custody or control of any third person); wherever located; which
<br />can be located or discovered by reasonably diligent effort; including, but not limited to:
<br />acceptances, accounting records and work papers, accounts, accounts payable,
<br />accounts receivable, administrative records, advertisements, advertising literature,
<br />attorneys' notes and memoranda, advertising materials, affidavits, agendas,
<br />agreements, analyses, announcements, annual or other periodic reports,
<br />applications, appointment books, appraisals, assignments, assignments of
<br />beneficial interest, audit reports, audio-visual materials, audits, awards, balance
<br />sheets, bank account records, bank statements, bills, bills of lading, bills of sale,
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