(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
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.
