CreditCourt.com - Baker vs. Trans Union, LLC

"You," "Your" or "Plaintiff" means plaintiff CHRISTINE BAKER and any of her authorized agents or representatives or any person who took any action pursuant to her authorization.

"Trans Union" means Defendant Trans Union LLC.

"Person" means any individual, partnership, corporation, trust, estate, cooperative association, group, proprietorship, government, governmental subdivision or agency, or other entity.

"Documents" shall include, without limitations regardless of origin or location, all written, typed, printed, or graphic matter (however produced or reproduced), and electrical or magnetic sound or video recordings, film, or photographic prints, and all other writings or recordings of every kind and description. The terms "document(s)" also shall include all copies of documents by whatever means made, except that where a document is identified or produced, identical copies thereof which do not contain any markings, additions, or deletions different from the original need not be separately produced. Without limiting the foregoing, the terms "document(s)" shall include all corporate data sheets, narratives, agreements, contracts, communications, correspondence, letters, telegrams, telexes, messages, memoranda, records, reports, books, summaries or other records, personal conversations, minutes or summaries or other records of telephone conversations or interviews, summaries or other records of meetings and conferences, summaries or other records of negotiations, other summaries diaries, diary entities, calendars, appointment books, time records, instructions, work assignments, visitor records, forecasts, statistical statements, financial statements, work sheets, work papers, graphs, maps, plats, charts, drawings, tables, accounting records, schedules, ledgers, audits, analytical records, consultants' reports, expert reports, witness statements, appraisals, bulletins, brochures, pamphlets, circulars, trade letters, press releases, notes, notices, marginal notations, notebooks, telephone bills or records, bills, statements, records of obligations and expenditure, invoices, lists, journals, advertising, recommendations, files, printouts, compilations, tabulations, purchase orders, receipts, sell orders, confirmations, checks, canceled checks, letters or credit, envelopes or folders or similar containers, vouchers, analyses, studies, surveys, transcripts of hearings, transcripts of testimony, expense reports, microfilm, microfiches, articles, speeches, tape or disc recordings, sound recordings, video recordings, film, photographs, punch cards, programs and data compilations from which information can be obtained (including matter used in data processing), plus all indices, drafts, working/discussion copies, revisions or amendments of any of the above, and, generally, any other printed, written, handwritten, typewritten, recorded, stenographic, computer-generated, computer-stored, or electronically-stored matter, however and by whomever produced, prepared, reproduced, disseminated, or made, that are now, or formerly were, in your possession, custody or control or that are known by you to exist, and that can be located or discovered by reasonably diligent efforts.

In construing this request for documents: (a) a masculine, feminine or neuter pronoun shall not exclude the other gender; (c) "and" as well as "or" shall be construed disjunctively as necessary in order to bring within the scope of the request all responses which might otherwise be construed to be outside its scope.

All documents are to be divulged which are in the possession, custody or control of the Plaintiff, his attorneys, investigators, agents, employees or other representatives.

In the event that the response to any document request is "not applicable" or any similar phrase or answer, explain in detail why that document request is not applicable.

In the event that the response to any document request is "don't know" or "unknown" or any similar phrase or answer, explain in detail all efforts made by the named party or his attorneys or representatives to obtain the response to that document request.

These document requests are intended as continuing requests, requiring you to respond by supplemental response, setting forth any documents within the scope of the document request as may be required by you, your agents, attorneys or representatives following your original response.

As used herein, the phrases "relate to," "related to" "relating to," or the term "related" shall mean directly or indirectly mentioning or describing, evidencing, containing, constituting, pertaining to, being connected with, or reflecting upon a stated subject matter or person.

In producing documents and other materials, the deponent is requested to furnish all documents or things in his possession, custody or control, regardless of whether such documents or materials are possessed directly by him or his agents, employees, adjusters, representatives or investigators.

If any part of a document is responsive to any request, produce the whole document. If any requested document or thing cannot be produced in full, produce it to the fullest extent possible.

Claims of Privilege: If any documents responsive to the request are withheld on the basis of privilege, or for any other reason, furnish a description of each document withheld, describing, for each document, the nature, form and format of the document, its subject matter, and the date of the document, the name of the author or maker of the document, the name of each addressee or copy of the document, and the nature of the privilege claimed with respect to the document.

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