EFTA01076204.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA • CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN Defendant. DEFENDANT'S NOTICE OF SERVING FOURTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), files this Notice of Serving Fourth Set of Interrogatories to Plaintiff ill., pursuant to Rule 1.340, Florida Rules of Civil Procedure, and request the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to rel3 the following addressees on this p_ day of February , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss,M. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort le, FL 33301 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EFTA01076204  Phone Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 ch, FL 33401 Fax By: o e D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA01076205  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff' refers to III., and all her agents, employees, g on their behalf. representatives, attorneys, accountants or anyone else actin all his agents, 2. The term "Defendant" refers to Jeffrey Epstein and ns acting or purporting to representatives, employees, assigns, or other person or perso act on its behalf. nctively and 3. The words "and" and "or" shall be construed both conju r than exclusive. The singular disjunctively so as to make the request inclusive rathe de the singular. shall be construed to include the plural and the plural to inclu n statement or 4. The word "communication(s)" shall mean any oral or writte persons, including but not exchange of information of any type between two or more conversations, meetings or limited to documents, telephone or face-to-face conferences. kind, including, but 5. The word "document" shall mean any writing of every lope, file cabinet drawer not limited to, any letter, book, record, report, file folder, enve ing, chart, draft, schedule, label, memorandum, correspondence, communication, draw printout and any other photograph, tape, disc, card, wire, computer program computer instrument or device from electronic or mechanical recording or transcript of any other orialize human thought, which information can be perceived or which is used to mem tiff. The term "document" speech or action in the possession, custody, or control of Plain contained on the original also includes copies containing information in addition to that to in any document. The and all the attachments, enclosures, or documents referred ing and equal in scope to term "document" is also defined to be synonymous in mean 3 EFTA01076206  edure 34(a), including, without the usage of this term in Federal Rule of Civil Proc A draft or non-identical copy is limitation, electronic or computerized data compilations. a separate document within the meaning of this term. n, individual, 6. The word "person" shall mean any natural perso organization, joint venture, proprietorship, partnership, corporation, association, rnmental body or agency, or business trust or other business enterprise, gove of natural persons or other governmental, public, legal, or business entity, or group entities whether sui juris or otherwise. to, respond to, 7. The phrase "relate to" shall mean refer to, contain, allude mention, analyze, constitute, comment upon, discuss, show, disclose, explain, or characterize, either directly comprise, evidence, set forth, summarize, support, refute or indirectly, in whole or in part. s to state the 8. "Identify," when used to refer to a natural person, mean following: ss is not know, (a) his or her full name and address (or, if the present addre his or her last known address); employers, each (b) the full name and address of each of his or her each business corporation of which he or she is an officer or director, and in which he or she is a principal; not known, his or (c) his or her present position (or if the present position is the Interrogatory her last known position(s) at the time of the act to which response relates). to identify the (d) Such other information sufficient to enable Defendant person. a natural person 9. "Identify" when used to refer to any entity other than means to state the following: 4 EFTA01076207  (a) The full name of the entity, the type of the entity (e.g., corporation, partnership, etc.), the address of its principle place of business, its principle business activity, and if it is a corporation, the jurisdiction under which it has been organized and the date of incorporation. 10. "Identify," when used with reference to a Document or Communication means to state the following: (a) the nature of the document (e.g., letter, memorandum, etc), date of creation, author, place of preparation, the name and address of each addressee; (b) The identity of each signatory; (c) The title or heading of the document; (d) the general substance and subject matter; (e) Its present location and custodian (or, if not know, the last known); (f) the identity of each person to whom a copy of the document was sent and each date of its receipt and date of its transmittal or other disposition; (g) The circumstance of each such receipt and each transmittal or other disposition, including identity of the person transmitting and receiving it. 11. In lieu of identifying any document, Plaintiff may attach a true and correct copy of such document as an exhibit to its response to these Interrogatories, along with an explicit reference to the Interrogatory to which each document is responsive. 12. If the response to all or part of any Interrogatory is not known at the time the initial response is made, please include a statement to that effect, furnish the information that is known or available, and respond to the Interrogatory by amended or supplemental response in writing under oath within ten (10) days of the date on which the complete response becomes known or available. 5 EFTA01076208  FOURTH SET INTERROGATORIES TO PLAINTIFF cell phone numbers, dates of 1. List the names, business addresses, telephone and ss) and rates of pay employment, immediate supervisor (name and addre whom you have worked regarding all employers, including self-employment, for unded by Defendant on since you answered the First Set of Interrogatories propo and all sources of income or about December 10, 2008; this includes listing any you have received. ding mental health 2. Identify each physician or medical provider (inclu with whom you have professionals, drug or alcohol counselors and therapists) identify each facility consulted or who has treated or examined you, and inpatient or outpatient) (including drug or alcohol treatment facilities, whether n or treatment that is in where you have received any consultation, examinatio the date of consultation, any way related to this case; and state as to each reason for which you examination or treatment and the injury, condition or other Set of Interrogatories were examined or treated since you answered the First 2008. propounded by Defendant on or about December 10, gatories for the Information sought by use of the I Please refer to the "Definitions' section of these Interro term 'identify! 6 EFTA01076209  ers of all males, excluding 3. List separately the names, addresses and phone numb since you answered the Mr. Epstein, with whom you have had sexual activity or about December 10, First Set of Interrogatories propounded by Defendant on of sexual activity, the 2008 up through the current date. Describe the nature ideration from the person. date(s) and whether you received money or other cons r o r aiallworking website 4. Are you or any similar such as websites? you are currently a a. If so, please list all social networking websites of which previously a member; list all social networking websites of which you were the date you member and state the date you joined each site and cancelled your membership with each site. you used for b. Also, please list all usemames, screen names or "handles" ber. Also, each social networking site of which you were ever a mem each social please provide all uniform resource locators ("URL") for ' which you are, or were previously a member (i.e. ). 7 EFTA01076210 5. Are ou now or have ou ever been a member of an online dating website such as =Nor any similar website? a. If so, please list all online dating websites of which you are currently a member; list all online dating websites of which you were previously a member and state the date you joined each site and the date you cancelled your membership with each site. b. Also, please list all usernames, screen names or "handles" you used for each online dating website of which you were ever a member. Also, please provide all URLs for each social networkin website of which you are, or were previously a member (i.e. 6. Do you, or have you ever kept, a diary or journal since 2002? If so, please state whether the diary or journal was/is kept in hard copy or whether it was/is kept on a computer or other electronic device. a. If the diary or journal was kept in hard copy, describe its physical attributes (i.e. book, collection of loose paper, day planner) and state its current location. 8 EFTA01076211  b. If the diary or journal was/is kept on a computer or other electronic device, please identify the computer or electronic device, including the make and model; identify the owner of the computer or electronic device; and state the current location of the computer or electronic device. If the current location is unknown, please state the last known location of the computer or electronic device. c. Identify all individuals, including their full name, current address, home telephone number and cellular telephone number, that have read any portion of the diary or journal. d. Please state whether any copies were made of the diary or journal. If so, state the number of copies made and identify all individuals, including their full name, current address, home telephone number and cellular telephone number, who have, or at any time had, a copy of the diary or journal. 10. Please identify all computers you have used since 2002 and identify the owner of each computer; state the make, model and current location of each computer; if the current location of a particular computer is unknown, state each location in which you used last used each computer. 9 EFTA01076212 11. Please identify your five closest friends for the years 2006 - 2010, including their full name, current address, home telephone number and cellular telephone number. 12. Do you intend to call at trial other females who went to Mr. Epstein's residence? If so, please identify each individual, including their name, current address, home telephone number and cellular telephone number, and identify her counsel. Also, please state the substance of each witness's testimony. 10 EFTA01076213  VERIFICATION By: STATE OF FLORIDA ) ) ss COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this day of 2010 by who is personally known to me or has produced the following identification which is current or has been issued within the past five years and bears a serial or other identifying number. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) 11 EFTA01076214  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XYMMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S NOTICE OF SERVING FOURTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), files this Notice of Serving Fourth Set of Interrogatories to Plaintiff.., pursuant to Rule 1.340, Florida Rules of Civil Procedure, and request the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to the following addressees on thisClay of February , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach FL 33401-5012 Fax: — fax Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, ■. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EFTA01076215  Phone Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Pa B ch, FL 33401 Fax By: \ 0-4 te- o e D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA01076216  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff" refers to is, and all her agents, employees, representatives, attorneys, accountants or anyone else acting on their behalf. 2. The term "Defendant" refers to Jeffrey Epstein and all his agents, representatives, employees, assigns, or other person or persons acting or purporting to act on its behalf. 3. The words "and" and "or" shall be construed both conjunctively and disjunctively so as to make the request inclusive rather than exclusive. The singular shall be construed to include the plural and the plural to include the singular. 4. The word "communication(s)" shall mean any oral or written statement or exchange of information of any type between two or more persons, including but not limited to documents, telephone or face-to-face conversations, meetings or conferences. 5. The word "document" shall mean any writing of every kind, including, but not limited to, any letter, book, record, report, file folder, envelope, file cabinet drawer label, memorandum, correspondence, communication, drawing, chart, draft, schedule, photograph, tape, disc, card, wire, computer program computer printout and any other electronic or mechanical recording or transcript of any other instrument or device from which information can be perceived or which is used to memorialize human thought, speech or action in the possession, custody, or control of Plaintiff. The term "document" also includes copies containing information in addition to that contained on the original and all the attachments, enclosures, or documents referred to in any document. The term "document" is also defined to be synonymous in meaning and equal in scope to EFTA01076217  edure 34(a), including, without the usage of this term in Federal Rule of Civil Proc A draft or non-identical copy is limitation, electronic or computerized data compilations. a separate document within the meaning of this term. person, individual, 6. The word "person" shall mean any natural organization, joint venture, proprietorship, partnership, corporation, association, rnmental body or agency, or business trust or other business enterprise, gove of natural persons or other governmental, public, legal, or business entity, or group entities whether sui juris or otherwise. e to, respond to, 7. The phrase "relate to" shall mean refer to, contain, allud mention, analyze, constitute, comment upon, discuss, show, disclose, explain, characterize, either directly comprise, evidence, set forth, summarize, support, refute or or indirectly, in whole or in part. s to state the 8. "Identify," when used to refer to a natural person, mean following: ss is not know, (a) his or her full name and address (or, if the present addre his or her last known address); oyers, each (b) the full name and address of each of his or her empl each business corporation of which he or she is an officer or director, and in which he or she is a principal; known, his or (c) his or her present position (or if the present position is not Interrogatory her last known position(s) at the time of the act to which the response relates). t to identify the (d) Such other information sufficient to enable Defendan person. natural person 9. "Identify" when used to refer to any entity other than a means to state the following: EFTA01076218  (a) The full name of the entity, the type of the entity (e.g., corporation, partnership, etc.), the address of its principle place of business, its principle business activity, and if it is a corporation, the jurisdiction under which it has been organized and the date of incorporation. 10. "Identify," when used with reference to a Document or Communication means to state the following: (a) the nature of the document (e.g., letter, memorandum, etc), date of creation, author, place of preparation, the name and address of each addressee; (b) The identity of each signatory; (c) The title or heading of the document; (d) the general substance and subject matter; (e) Its present location and custodian (or, if not know, the last known); (f) the identity of each person to whom a copy of the document was sent and each date of its receipt and date of its transmittal or other disposition; (g) The circumstance of each such receipt and each transmittal or other disposition, including identity of the person transmitting and receiving it. 11. In lieu of identifying any document, Plaintiff may attach a true and correct copy of such document as an exhibit to its response to these Interrogatories, along with an explicit reference to the Interrogatory to which each document is responsive. 12. If the response to all or part of any Interrogatory is not known at the time the initial response is made, please include a statement to that effect, furnish the information that is known or available, and respond to the Interrogatory by amended or supplemental response in writing under oath within ten (10) days of the date on which the complete response becomes known or available. EFTA01076219  FOURTH SET INTERROGATORIES TO PLAINTIFF cell phone numbers, dates of 1. List the names, business addresses, telephone and ss) and rates of pay employment, immediate supervisor (name and addre whom you have worked regarding all employers, including self-employment, for unded by Defendant on since you answered the First Set of Interrogatories propo and all sources of income or about December 10, 2008; this includes listing any you have received. (including mental health 2. Identify' each physician or medical provider with whom you have professionals, drug or alcohol counselors and therapists) identify each facility consulted or who has treated or examined you, and inpatient or outpatient) (including drug or alcohol treatment facilities, whether n or treatment that is in where you have received any consultation, examinatio the date of consultation, any way related to this case; and state as to each reason for which you examination or treatment and the injury, condition or other Set of Interrogatories were examined or treated since you answered the First . propounded by Defendant on or about December 10, 2008 es for the information sought by use of the ' Please refer to the "Definitions" section of these Interrogatori term Identify.° EFTA01076220  ers of all males, excluding 3. List separately the names, addresses and phone numb ty since you answered the Mr. Epstein, with whom you have had sexual activi on or about December 10, First Set of Interrogatories propounded by Defendant e of sexual activity, the 2008 up through the current date. Describe the natur ideration from the person. date(s) and whether you received money or other cons o a ' networking website 4. Are you or any similar such as websites? you are currently a a. If so, please list all social networking websites of which were previously a member; list all social networking websites of which you and the date you member and state the date you joined each site cancelled your membership with each site. you used for b. Also, please list all usemames, screen names or "handles" a mem ber. Also, each social networking site of which you were ever each social please provide all uniform resource locators ("URL") for which you are, or were previously a member (i.e. ). EFTA01076221 5. Are ou now or have ou ever been a member of an online dating website such as ME or any similar website? a. If so, please list all online dating websites of which you are currently a member, list all online dating websites of which you were previously a member and state the date you joined each site and the date you cancelled your membership with each site. b. Also, please list all usernames, screen names or "handles" you used for each online dating website of which you were ever a member. Also, please provide all URLs for each social networkin website of which you are, or were previously a member (i.e. 6. Do you, or have you ever kept, a diary or journal since 2002? If so, please state whether the diary or journal was/is kept in hard copy or whether it was/is kept on a computer or other electronic device. a. If the diary or journal was kept in hard copy, describe its physical attributes (i.e. book, collection of loose paper, day planner) and state its current location. EFTA01076222  b. If the diary or journal was/is kept on a computer or other electronic device, please identify the computer or electronic device, including the make and model; identify the owner of the computer or electronic device; and state the current location of the computer or electronic device. If the current location is unknown, please state the last known location of the computer or electronic device. c. Identify all individuals, including their full name, current address, home telephone number and cellular telephone number, that have read any portion of the diary or journal. d. Please state whether any copies were made of the diary or journal. If so, state the number of copies made and identify all individuals, including their full name, current address, home telephone number and cellular telephone number, who have, or at any time had, a copy of the diary or journal. 10. Please identify all computers you have used since 2002 and identify the owner of each computer; state the make, model and current location of each computer; if the current location of a particular computer is unknown, state each location in which you used last used each computer. EFTA01076223 11. Please identify your five closest friends for the years 2006 — 2010, including their full name, current address, home telephone number and cellular telephone number. 12. Do you intend to call at trial other females who went to Mr. Epstein's residence? If so, please identify each individual, including their name, current address, home telephone number and cellular telephone number, and identify her counsel. Also, please state the substance of each witness's testimony. EFTA01076224  VERIFICATION By: STATE OF FLORIDA ) ss COUNTY OF PALM BEACH SWORN TO AND SUBSCRIBED before me this day of 2010 by , who is personally known to me or has produced the following identification which is current or has been issued within the past five years and bears a serial or other identifying number. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) EFTA01076225  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S THIRD INTERROGATORIES DIRECTED TO PLAINTIFF Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), pursuant 33 and M. Fla. 26.1.G., hereby serves this Third Set of Interrogatories directed to Plaintiff, Jane Doe, and requests that they be answered separately, fully and under oath within thirty (30) days of service pursuant toill=1. 33 and . Fla. L.R. 26.1.G. For purposes of this discovery, Definitions and Instructions are pursuant to S. Fla. L.R. 26.1.G. PRELIMINARY STATEMENT These interrogatories are deemed continuing. Pursuant to Rule 26(e) of the Federal Rules of Civil Procedure and applicable law, if any information sought by said interrogatories is not learned until after they are answered, or if any answers for any reason should later become incorrect, there shall be a continuing duty on the party answering said interrogatories to supplement or change answers previously submitted. EFTA01076226  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff" refers to Jane Doe, and all her agents, employees, representatives, attorneys, accountants or anyone else acting on their behalf. 2. The terms "Defendant" refers to Jeffrey Epstein and all his agents, representatives, employees, assigns, or other person or persons acting or purporting to act on its behalf. 3. The words "and" and "or shall be construed both conjunctively and disjunctively so as to make the request inclusive rather than exclusive. The singular shall be construed to include the plural and the plural to include the singular. The word "communication(s)" shall mean any oral or written statement or exchange of information of any type between two or more persons, including but not limited to documents, telephone or face-to-face conversations, meetings or conferences. 4. The word "document" shall mean any writing of every kind, including, but not limited to, any letter, book, record, report, file folder, envelope, file cabinet drawer label, memorandum, correspondence, communication, drawing, chart, draft, schedule, photograph, tape, disc, card, wire, computer program computer printout and any other electronic or mechanical recording or transcript of any other instrument or device from which information can be perceived or which is used to memorialize human thought, speech or action in the possession, custody, or control of the Plaintiff. The term "document" also includes copies containing information in addition to that contained on the original and all the attachments, enclosures, or documents referred to in any document. The term "document" is also defined to be synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a), 2 EFTA01076227 including, without limitation, electronic or computerized data compilations. A draft or non-identical copy is a separate document within the meaning of this term. 5. The word "person" shall mean any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, business trust or other business enterprise, governmental body or agency, or governmental, public, legal, or business entity, or group of natural persons or other entities whether sui juris or otherwise. 6. The phrase "relate to" shall mean refer to, contain, allude to, respond to, comment upon, discuss, show, disclose, explain, mention, analyze, constitute, comprise, evidence, set forth, summarize, support, refute or characterize, either directly or indirectly, in whole or in part. 7. "Identify," when used to refer to a natural person, means to state the following: (a) his or her full name and address (or, if the present address is not know, his or her last known address); (b) the full name and address of each of his or her employers, each corporation of which he or she is an officer or director, and each business in which he or she is a principal; (c) his or her present position (or if the present position is not known, his or her last known position(s) at the time of the act to which the Interrogatory response relates). (d) Such other information sufficient to enable the Plaintiffs to identify the person. 8. "Identify" when used to refer to any entity other than a natural person means to state the following: 3 EFTA01076228  (a) The full name of the entity, the type of the entity (e.g., corporation, partnership, etc.), the address of its principle place of business, its principle business activity, and if it is a corporation, the jurisdiction under which it has been organized and the date of incorporation. 10. "Identify," when used with reference to a Document or Communication means to state the following: (a) the nature of the document (e.g., letter, memorandum, etc), date of creation, author, place of preparation, the name and address of each addressee; (b) The identity of each signatory; (c) The title or heading of the document; (d) the general substance and subject matter; (e) Its present location and custodian (or, if not know, the last known); (f) the identity of each person to whom a copy of the document was sent and each date of its receipt and date of its transmittal or other disposition; (g) The circumstance of each such receipt and each transmittal or other disposition, including identity of the person transmitting and receiving it. 11. In lieu of identifying any document, Plaintiff may attach a true and correct copy of such document as an exhibit to its response to these Interrogatories, along with an explicit reference to the Interrogatory to which each document is responsive. 12. If the response to all or part of any Interrogatory is not known at the time the initial response is made, please include a statement to that effect, furnish the information that is known or available, and respond to the Interrogatory by amended or supplemental response in writing under oath within ten (10) days of the date on which the complete response becomes known or available. 4 EFTA01076229  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff" refers to Jane Doe, and all her agents, employees, representatives, attorneys, accountants or anyone else acting on their behalf. 2. The term "Defendant" refers to Jeffrey Epstein and all his agents, representatives, employees, assigns, or other person or persons acting or purporting to act on its behalf. 3. The words "and" and "or" shall be construed both conjunctively and disjunctively so as to make the request inclusive rather than exclusive. The singular shall be construed to include the plural and the plural to include the singular. 4. The word "communication(s)" shall mean any oral or written statement or exchange of information of any type between two or more persons, including but not limited to documents, telephone or face-to-face conversations, meetings or conferences. 5. The word "document" shall mean any writing of every kind, including, but not limited to, any letter, book, record, report, file folder, envelope, file cabinet drawer label, memorandum, correspondence, communication, drawing, chart, draft, schedule, photograph, tape, disc, card, wire, computer program computer printout and any other electronic or mechanical recording or transcript of any other instrument or device from which information can be perceived or which is used to memorialize human thought, speech or action in the possession, custody, or control of Plaintiff. The term "document" also includes copies containing information in addition to that contained on the original and all the attachments, enclosures, or documents referred to in any document. The term 5 EFTA01076230  "document' is also defined to be synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a), including, without limitation, electronic or computerized data compilations. A draft or non-identical copy is a separate document within the meaning of this term. 6. The word "person" shall mean any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, business trust or other business enterprise, governmental body or agency, or governmental, public, legal, or business entity, or group of natural persons or other entities whether suifurls or otherwise. 7. The phrase "relate to" shall mean refer to, contain, allude to, respond to, comment upon, discuss, show, disclose, explain, mention, analyze, constitute, comprise, evidence, set forth, summarize, support, refute or characterize, either directly or indirectly, in whole or in part. 8. "Identify," when used to refer to a natural person, means to state the following: (e) his or her full name and address (or, if the present address is not know, his or her last known address); (f) the full name and address of each of his or her employers, each corporation of which he or she is an officer or director, and each business in which he or she is a principal; (g) his or her present position (or if the present position is not known, his or her last known position(s) at the time of the act to which the Interrogatory