Uniform Definitions in Discovery Requests

(a) Incorporation by Reference and Limitations: The full text of the definitions set forth in paragraph (c) of this Rule is incorporated by reference into all discovery requests, but shall not preclude: (1) the definition of other terms specific to a particular case, (2) the use of abbreviations, or (3) a narrower definition of a term defined in paragraph (c). (b) Effect on Scope of Discovery: This Rule does not broaden or narrow the scope of discovery permitted by the Federal Rules of Civil Procedure or these Local Rules. (c) Definitions: The following definitions apply to all discovery requests: (1) “communication” means the transmittal of information (in the form of facts, ideas, inquiries or otherwise); (2) “document” is synonymous in meaning and equal in scope to the usage of this term in Fed. R. Civ. P. 34(a). A draft or non-identical copy is a separate document; (3) “identify,” when referring to a person, means to give, to the extent known, the person’s full name and present or last known address.

Once a person has been identified in accordance with this subparagraph, only the name of that person need be given in response to subsequent requests concerning that person’s identity; (4) “identify,” when referring to documents, means to give, to the extent 68 known, the: (i) type of document, (ii) general subject matter, (iii) author(s), addressee(s) and recipient(s), and (iv) date the document was prepared; (5) “plaintiff,” “defendant,” a party’s full or abbreviated name, or a pronoun referring to a party, means the party, and where applicable, its officers, directors, employees and partners. This definition does not impose a discovery obligation on any person who is not a party to the case; (6) “person” means any natural person or any business, legal or governmental entity or association; and (7) “concerning” means referring to, describing, evidencing or constituting.