On 1/27/06, Bil Kellermann <[log in to unmask]> wrote:
> At the end of the day, every one of my Requests for Production starts with "Please produce any and all documents in your possession, custody or control that refer or relate to..." The only documents an entity is reasonably expected to keep in its possession, custody or control are its records...
not trying to be argumentative here, but why use the term "documents"
when an entity is reasonably expected to produce "records"? This is
where I think the confusion begins.
--
Peter Kurilecz CRM CA
Richmond, Va
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