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Persons who made or assisted in the determination of the status of the material as work product. 3. ttorney!s" or other individual!s"who created?
#. Persons who had access to said work product $. Persons or agencies to which the alleged work product was provided %. &ow transferred? '. (he date and court proceeding wherein Defendant raised the )work product) privilege or otherwise o*+ected to the disclosure of the alleged work product., if any. -. (he date and ii. Pu*lic .ecords 1. Please identify *y make, model, serial num*er, and purchase date of the computer allegedly wiped of pu*lic records. 2. Please descri*e with specificity what actions and efforts were undertaken !if any" to determine whether Plaintiff had deleted Pu*lic .ecords. a. If any such actions and efforts were undertaken, please identify the individual!s" who participated in such actions and the dates of their participation. 3. Please descri*e with specificity what actions and efforts were undertaken !if any" to determine whether the pu*lic records alleged to have *een deleted were maintained, stored, or preserved in any other location. a. If any etc. #. If you are alleging that Plaintiff violated pu*lic records law in any manner other than, or in addition to, the deletion of pu*lic records, please specify the actions of Plaintiff constituting the alleged violation. $. /opies of all pu*lic records alleged to have *een deleted.
a. 0or each individual pu*lic record alleged to have *een deleted specify whether and where copies of such pu*lic record were maintained or kept in any other storage media, facility, server, computer, or )cloud). %. /opies of all documents showing or identifying the creator and custodian of each and every pu*lic record alleged to have *een deleted '. /opies of all documents and communications relating to any effort or investigation to determine or identify or retrieve the pu*lic records alleged to have *een deleted. -. /opies of all policies relating to the repair of non1functioning or misfunctioning computers. 2. /opy of +o* description for the I( director !or other designated +o* title of Plaintiff immediately prior to his discharge" *. .e3uest to Produce 2. 4ruid*os report 3. nswer to /ounterclaims, .eply, Incorporated 5otion to Dismiss !0ailure to 6tate a /ause of ction, failure to attach copies and e7hi*its", affirmative defenses !fraud on the court, illegality"
#. 5otion to 6trike $. $'.18$ %. 1.1'8 additional parties may *e *rought in relative to counterclaims !see also 1.1-8" '. 5otion for 5ore Definite 6tatement?