CORRESPONDENCE - NON-AGENDA - Laserfiche WebLink

Home Browse Search

9. For the purposes of this entire set of document requests, "VDC OPERATING AGREEMENT" means the Second Amended and Restated Operating Agreement for VDC at The Met, LLC. 10. For the purposes of this entire set of document requests, a document 'concerns", "refers to", "relates to" or is "concerning", "referring to" or "relating to" a particular fact, matter or event when it proves or disproves, or tends to prove or disprove, the fact, matter, or event, or contains information concerning, explaining, or providing a background for understanding that fact, matter or event, or is evidence of or a result of that fact, matter, or event, or could lead to additional relevant information concerning, explaining, or providing a background for understanding that fact, matter or event, or was produced altered or signed as a part of or as a result of that fact, matter or event. INSTRUCTIONS 1. The DOCUMENTS produced pursuant to these requests must be segregated and identified according to the specific request to which they are responsive. Duplicate copies of DOCUMENTS which are responsive to more than one request need not be produced more than once if the specific requests to which such DOCUMENTS relate are designated. 2. The DOCUMENTS requested hereby specifically include, but are not limited to, those DOCUMENTS in YOUR possession, custody or control, or in the possession, custody or control of YOUR employees, agents, representatives, attorneys, accountants, auditors, affiliates, advisers, consultants and any other person or entity acting, or who has acted, on YOUR behalf. 3. If any of the DOCUMENTS requested below are claimed to be privileged or are otherwise withheld, set forth with respect to each such DOCUMENT facts of sufficient specificity to permit the Court to make a full determination as to whether the claim of privilege is valid, including each and every fact or basis upon which said privilege is claimed. 4. In the event that any DOCUMENT or other thing called for by any request has been destroyed, discarded, or otherwise disposed of, that DOCUMENT or other thing is to be identified as completely as possible, and the following information is to be provided.