Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 97 of 123 PageID: 4280 Your if You now have or have had the right to secure or obtain the document or a copy “control” thereof on demand from another Person or governmental entity having actual physical possession thereof. means all information of any kind of which You are aware “Factual Basis” whether such information is admissible or inadmissible in evidence. A response setting forth the shall include the name and address of any such Persons involved, the “Factual Basis” identification of any Documents involved, the time and date of the described circumstances, the name and address of any witnesses to the circumstances described, and an exhaustive description of the circumstances and factual aspects of the subject of inquiry. All written statements pertaining to the factual basis as defined in this paragraph must be identified in your response. To or the or a Person, if that Person is “identify,” “state identity of” “to describe” a natural Person, means to state: His or her name and all other names by which he or she is known; His or her present or last known resident address and telephone number; His or her present or last known business address and telephone number; and His or her present or last known occupation, position, and business affiliation. To or the or a Person, if that Person is “identify,” “state identity of” “to describe” not a natural Person, means to: State its full name and specify its nature (e.g., corporation, partnership, limited liability company, etc.); Set forth the general nature of its business (e.g., products manufactured or sold, services rendered, etc.);
Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 97 of 123 PageID: 4280 Your “control” if You now have or have had the right to secure or obtain the document or a copy thereof on demand from another Person or governmental entity having actual physical possession thereof. “Factual Basis” means all information of any kind of which You are aware whether such information is admissible or inadmissible in evidence. A response setting forth the “Factual Basis” shall include the name and address of any such Persons involved, the identification of any Documents involved, the time and date of the described circumstances, the name and address of any witnesses to the circumstances described, and an exhaustive description of the circumstances and factual aspects of the subject of inquiry. All written statements pertaining to the factual basis as defined in this paragraph must be identified in your response. To “identify,” or “state the identity of” or “to describe” a Person, if that Person is a natural Person, means to state: His or her name and all other names by which he or she is known; His or her present or last known resident address and telephone number; His or her present or last known business address and telephone number; and His or her present or last known occupation, position, and business affiliation. To “identify,” or “state the identity of” or “to describe” a Person, if that Person is not a natural Person, means to: State its full name and specify its nature (e.g., corporation, partnership, limited liability company, etc.); Set forth the general nature of its business (e.g., products manufactured or sold, services rendered, etc.);
212-Letter-of-Gerald-A-Marks-in-Response-to-Letter-Seeking-Stay-1-1-29-15.docx