Giuffre_Maxwell_Batch6_p00368.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 8 of 11
10.
With respect to any Documents withheld on the basis of a privilege, provide a log
consistent with Local Rule 26.2 of the Federal Rules of Civil Procedure for the Southern
District of New York.
INSTRUCTIONS
Production of documents and items requested herein shall be made to Laura Menninger,
Haddon, Morgan & Foreman, PC, 150 E. 10% Ave., Denver, CO 80220, no later than
February 13, 2017, at 9:00 a.m. Alternatively, you may provide the records
electronically by that date and time to Laura Menninger at
LMenninger@HMFLaw.com or by such other method as agreed upon with counsel for
the subpoenaing party.
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.
If any Document was in your possession or control, but is no longer, state what
disposition was made of said Document, the reason for the disposition, and the date of
such disposition.
In producing Documents, if the original of any Document cannot be located, a copy
shall be produced in lieu thereof, and shall be legible and bound or stapled in the same
manner as the original.
Any copy of a Document that is not identical shall be considered a separate document.
All Documents shall be produced in the same order as they are kept or maintained by
you in the ordinary course of business.
Responsive electronically stored information (ES]) shall be produced in its native form;
that is, in the form in which the information was customarily created, used and stored
by the native application employed by the producing party in the ordinary course of
business.
Defendant does not seek and does not require the production of multiple copies of
identical Documents.
Unless otherwise specified, the time frame of this request is from 1999 to present.
This Request is deemed to be continuing. If, after producing these Documents, you
obtain or become aware of any further information, Documents, things, or information
responsive to this Request, you are required to so state by supplementing your
responses and producing such additional Documents to Defendant.
Document Details
| Filename | Giuffre_Maxwell_Batch6_p00368.png |
| File Size | 1132.9 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 2,211 characters |
| Indexed | 2026-02-04 12:47:02.051858 |