I don't think any lawyer would want to sue me because of D. Miller. My discover questions would be overwhelming. I first would request;
As used in this attachment, the terms "Documents" means all records and the forms of expression in your possession, custody and control, whether originals, drafts or finished versions, or annotated or nonconforming copies, and however created, produced or stored (manually, mechanically, electronically or otherwise) and by whomever prepared, produced, sent, dated or received, including without limitation, documents, books, papers, workpapers, files, permanent files, personal files, notes, review notes, confirmations, account statements, order tickets, correspondence, memoranda, reports, records, journals, registers, analyses, plans, manuals, policies, ledger sheets, schedules, invoices, telegrams, faxes, telexes, wires, electronic mail messages, telephone logs, telephone messages, message slips, minutes, notes or transcripts of conversations or communications or meetings, tape recordings, disks, and other electronic media, microfilm, microfiche, storage devices, press releases, contracts, agreements, calendars, date books, appointment books, diaries, notices, bank statements, summaries, wire transfers, checks, drafts for money, bills, billing, files and records of payments, Testimonials, alerts, copies of any posts you ever mail on the Internet, any correspondence you have ever had with Stock promoters, disclaimers, ect..
for starters
floyd |
