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Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 9 of 24 TO: JEAN LUC BRUNEL EXHIBIT A % “Person(s)” includes natural persons, proprietorships, governmental agencies, corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other legal or business entity. 10. “You” or “Your” hereinafier means Jean Luc Brunel and any employee, agent, attorney, consultant, related entities or other representative of Jean Lue Brunel. INSTRUCTIONS 1. Production of documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York. 2: Unless indicated otherwise, the Relevant Period for this Request is from 1996 to the present. A Document should be considered to be within the relevant lime frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. 3. This Request calls for the production of all responsive Documents in your possession, custody or control without regard to the physical location of such documents. 4. If any Document requested was in your possession or control, but is no longer in its possession or control, state what disposition was made of said Document, the reason for such disposition, and the date of such disposition. ay For the purposes of reading, interpreting, or construing the scope of these requests, the terms used shall be given their most expansive and inclusive interpretation. his includes, without limitation the following: a) Wherever appropriate herein, the singular form of a word shall be interpreted as plural and vice versa. b) “And” as well as “or” shall be construed either disjunctively or conjunctively as necessary to bring within the scope hereo! any