present or last known address, and when referring

to a natural person, additionally, the present or last known place of employment. Once a person has been identified in accordance with this subdi- vision, only the name of that person need be listed in response to subsequent discovery requesting the identification of that person. (4) Identify (with respect to documents or elec- tronically stored information). When referring to documents or electronically stored information, to ‘‘identify’’ means: to provide, to the extent known, information about the (A) type of document or electronically stored information; (B) its general subject matter; (C) the date of the document or electronically stored information; and (D) author(s), addressee(s) and recipient(s). (5) Identify (with respect to oral communica- tions). When referring to an oral communica- tion, to ‘‘identify’’ means: (A) to state the date and place of the oral communication; (B) to identify all persons hearing, present or participating in the communication; (C) to state whether the commu- nication was in person, by telephone, or by some other means or medium; (D) to summarize what was said by each such person, or provide a tran- script if one is available. (6) Identify (with respect to an act or event). When referring to an act or event, to ‘‘identify’’ means: (A) to describe the act or event, including its location and its date; (B) to identify the persons participating, present or involved in the act or event; (C) to identify all oral communications which were made at the act or event identified; and (D) to identify all documents concerning the act or event identified. (7) Person. The term ‘‘person’’ is defined as any natural person or any business, legal or gov- ernmental entity or association. (8) Concerning. The term ‘‘concerning’’ means relating to, referring to, describing, evidencing or constituting. (9) You. The term ‘‘you’’ means the party or person to whom a discovery request is directed, except that: (A) if the party is the representative of the estate of a decedent, ward, or incapable person, ‘‘you’’ shall also refer to the party’s dece- dent, ward or incapable person, unless the context of the discovery request clearly indicates other- wise; and (B) notwithstanding subsection (b) above, the propounding party may specify a differ- ent definition of the term ‘‘you.’’ (d) The following rules of construction apply to all discovery requests: (1) All/Each. The terms ‘‘all’’ and ‘‘each’’ shall both be construed as all and each. (2) And/Or. The connectives ‘‘and’’ and ‘‘or’’ shall be construed either disjunctively or conjunc- tively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside its scope. (3) Number. The use of the singular form of any word includes the plural and vice versa. (4) Gender. Unless the context clearly requires otherwise, the use of any pronoun or gender-iden- tified form of any word includes both the male and female genders. (P.B. 1978-1997, Sec. 216.) (Amended June 20, 2011, to take effect Jan. 1, 2012; amended June 14, 2013, to take effect Jan. 1, 2014.)