Free Notice to Take Deposition - District Court of Delaware - Delaware

‘ ‘ Case 1 :04-cv-01374-SLR Document 25-2 Filed 06/15/2005 Page 1 of 1
ATTACHMENT A
DEFINITIONS
l. The terms "document" or "documents" means any written, recorded, electronic,
filmed, or graphic matter, whether produced, reproduced, or on paper, cards, tapes, film,
electronic facsimile, email, computer storage devices or any other media, including but not
limited to memoranda, notes, minutes, records, photographs, correspondence, telegrarns,
bookkeeping entries, financial statements, tax returns, checks, check stubs, reports, studies,
responses to questionnaires, charts, graphs, statements, notebooks, handwritten notes,
applications, agreements, books, pamphlets, periodicals, appointment calendars, notes, diaries,
records and recordings of oral conversations, work papers, and also including but not limited to,
originals and all copies which are different in any way from the original whether by
interlineation, receipt stamp, notation, indication of copies sent or received, or otherwise, and
drafts, which are in the possession, custody or control of you, your present or former agents,
representatives, or attorneys, or any and all persons acting on your behalf, including documents at
any time in the possession, custody or control of such individuals or entities or known by you to
exist.
2. The term “concerning" means relating to, referring to, describing, evidencing, or
constituting.
2 DOCUMENTS TO BE PRODUCED
1. Any and all documents concerning the medical or health care information and
medical or health care records of Pamela Graeber ("Graeber") [SSN#l 80-36-2179] relating to her
heart condition and/or related treatment or relating to other matters which may have a historical
or causal comiection to her heart condition and/or related treatment, including, but not limited to,
the reports of physicians, including psychiatrists, psychologists, therapists, social workers, or any
other mental or physical health care professional, and any related materials of any kind, including
hospital records, charts, x-rays, technicians’ reports and related materials, physicians’ notes, e
including psychiatrists’, psychologists’, social workers’ or nurses’ notes, lab reports, test results,
audio tapes, video tapes, index cards, billing records, and insurance forms and records. The
released information is to be used in connection with the above—referenced litigation.