Fill and Sign the Worley Brown Llc V the Mississippi Department of Form

1 IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI , PLAINTIFFVS. CIVIL ACTION NO. , DEFENDANT FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS TO DEFENDANT COMES NOW the Plaintiff, (" "), by and through its attorneys of record herein, and requests that Defendant, (" "), produce the following documents and other things requested herein for the purpose of inspection and copying. Such material should be produced in the offices of Mississippi at a.m./p.m. forty-five (45) days after service hereof, pursuant to Rule 34 of the Mississippi Rules of Civil Procedure. DEFINITIONS The following definitions apply throughout request for production of documents and things and shall be adopted in responding to said discovery.A. "Person" shall mean any natural person or any entity, whether business entity (corporation, association, firm, partnership or otherwise), governmental entity, other legal entity or agency, bureau, committee, department, division, subdivision or subsidiary thereof.B. "You" or "Your" means the above-named Defendant and his/her agents, employees and representatives.C. "Representative" means any affiliate, attorney, accountant, agent, employee, servant, spouse or other person acting for or on behalf of the Defendant or with whom the Defendant has entrusted documents for safekeeping or record keeping purposes. 2 D. "Relating to" includes, but without limitation, mentioning, discussing, commenting on, referring to, pertaining to, alluding to, relating to, relevant to, or in any way touching upon or connected with.E. "Documents" means any records, files, documents, instruments, letters, memoranda, notes, reports, summaries, statements, correspondence, minutes, logs, agreements, contracts, telegrams, TWXs, notices, proofs, forms, cards, charts, drawings, diagrams, graphs, graphic representations, books, ledgers, accounts, check stubs, vouchers, pay records, photographs, tape recordings, microfilms, computer printouts, papers, or other written, typed, printed, or recorded material of any kind whatsoever in the possession, custody or control of the Defendant or the Defendant's representatives, regardless of by, or from whom the "document" was prepared, regardless of the addressor(s) and addressee(s), regardless of whether it is an original or a copy of an original, and regardless of how the Defendant or the Defendant's representatives acquired possession, custody or control thereof.F. "Identify" means, with respect to persons, to give the name, current residence and business addresses, and current residence and business telephone numbers for the persons requested to be identified. REQUESTS REQUEST NO. 1: Each and every writing, document or other physical evidence referred to, described or identified in your Answer or other responsive pleading and in your Answers to Plaintiff's First Set of Interrogatories served simultaneously with this request. REQUEST NO. 2: All documents which support or tend to support any allegations contained in your Plaintiff's Complaint or in your Answer or other responsive pleading thereto. 3 REQUEST NO. 3: All correspondence, memoranda or documents of any nature, which you sent to, received from or exchanged with or anyone acting on its behalf. REQUEST NO. 4: All correspondence, memoranda or documents of any nature which you sent to, received from or exchanged with or anyone acting on his/her behalf. REQUEST NO. 5: All correspondence, memoranda or documents of any nature which you sent to, received from or exchanged with or anyone acting on his/her behalf. REQUEST NO. 6: All correspondence, memoranda or documents of any nature, which you sent to, received from or exchanged with any customer or known potential customer of