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<br />or known by you to exist, including, without limiting the generality of the foregoing, all drafts,
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<br />contracts, diaries, agreements, calendars, desk pads, correspondence, computer printouts, telegrams,
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<br />teletypes, memoranda, notes, studies, reports, lists, minutes, maps, graphs and entries in books of
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<br />account relating in any way to the subject matter of these requests for production.
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<br />B. The terms "you" and "your" means, Speedway SuperAmerica LLC, its officers,
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<br />employees and agents and all other persons acting or purporting to act on your behalf or participating
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<br />in any matter relating to the subject matter of this lawsuit
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<br />C. The terms "identify" or "identification" and "describe" or "description":
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<br />1. When used in reference to a document, mean to state the type of document, its
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<br />nature or substance, its title or caption and any identifying me numbers or symbols, the date it
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<br />was prepared, the date it bears or, if undated, the date it was written or created, the names,
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<br />employers and positions of the person responsible for its preparation (excluding merely clerical
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<br />personnel), addresses of all copies, recipients of all copies, title, the present location of all
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<br />copies to the extent known, the name and address of the custodian of all copies, to the extent
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<br />known, and the substance of the contents thereof. ill lieu of identifying any particular copy of
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<br />a document according to the foregoing, a copy thereof may be furnished.
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<br />D. The term "relating to" means constituting, defining, containing, embodying, reflecting,
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<br />stating, referring to, dealing with, or in any way pertaining to.
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<br />II. INSTRUCTIONS
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<br />1. ill the event that any document called for by this request has been discarded or
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<br />destroyed, that document is to be identified as follows: addressor, addressee, indicated or blind copies,
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<br />date, subject matter, number of pages, attachments or appendices, all persons to whom distributed,
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<br />DJD-148765
<br />BE295-
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