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telephone messages, trademarks and materials relating thereto, trade secrets and
<br />materials relating thereto, telegrams, telephone bills and toll call records,
<br />telephone logs and records, telex communications, tests and results thereof, title
<br />policies, title reports, trade letters, transactional records, transcripts,
<br />transcriptions, travel records, trial exhibits, trial transcripts, trust agreements,
<br />trusts, verdicts, video tapes, video discs, voice recordings, warrants, warranties,
<br />wills, worksheets, work papers, writs, writings, and written memorials of oral
<br />communications (including notations or statements of any kind whatsoever of
<br />communications containing conversations, dialogues, discussions, interviews,
<br />consultations, or other understandings between or among two or more persons,
<br />whether oral or written).
<br />2. For the purposes of this entire set of document requests, "THE MET AT
<br />GENEVA COMMONS" means that certain piece of real property located at 200 East First
<br />American Way, City of Santa Ana, County of Orange, State of California.
<br />3. For the purposes of this entire set of document requests, "PROJECT" means that
<br />certain investment in the real property as more fully described in the Second Amended and
<br />Restated Operating Agreement for VDC at the Met, LLC, attached to the Plaintiffs Verified
<br />Complaint as Exhibit A.
<br />4. For the purposes of this entire set of document requests, "OGULNICK" means
<br />Ryan Ogulnick, individually, in his capacity as a manager of VDB Santa Ana, LLC, and/or in his
<br />capacity as an officer of Vineyards Development, Inc.
<br />5. For the purposes of this entire set of document requests, "YOU' and "YOUR"
<br />means Union Bank, as well as any advisors, agents, employees, servants, officers, directors,
<br />other persons and/or employees working at Union Bank.
<br />6. For the purposes of this entire set of document requests, "PROTILUS" means
<br />Protilus Investors, LLC and Protilus, L.P.
<br />7. For the purposes of this entire set of document requests, "ILUS INVESTORS"
<br />means Ilus Investors, LP.
<br />8. For the purposes of this entire set of document requests, "ILUS GP" means Ilus
<br />GP US, LLC.
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