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Date: Fri, 2 May 2003 17:36:59 -0400
From: sdunne@9-11 commission. gov^?
To: staff@9-11commission.gov£f
Subject: draft format for document requests

Here's a draft format for document requests; please let me know if you have any
comments or suggestions on the format. We envison sending most document
requests by email to the agency POC and copied to Adam Ciongoli at DOJ
simultaneously. To the extent you would like help wording particular requests
(for example, if you need a lawyerly definition^of "documents" or "computer \l
files"), please let me (' ,
r—'
[Agency or Entity] DOCUMENT'REQUEST No. XX
~ «• • •
n the ^
f
] ("respondent") prov'i-do the

documents -*•"•> ta-t-oT- i-h^»—['piuduuLiuii UdLtfl r*p

1. [specific document or class of documents]

2. [specific document or class of documents]

3. [etc.]

The Commission requests that documents requested above be provided as soon as


they are available, even though all requested documents may not be provided at,
the same time, through mean^ of a "rolling" production.

If any requested documents are withheld from production, even temporarily,


based on an alleged claim of privilege or for any other reason, the Commission
requests that the respondent, as soon as possible and in no event later than
the production date, identify and describe each such document or class of
documents, as well as the alleged basis for not producing it, with sufficient
specificity to allow a meaningful challenge to any such withholding.

If the respondent does not have possession, custody or control of any


requested documents but has information about where such documents may be
located, the Commission requests that the respondent provide such
information as soon as possible and in no event later than the production date.

If the respondent has any questions or concerns about the interpretation or


scope of these document requests, the Commission requests that any such
questions or concerns be raisedias soon as possible so that any
such issues can be addressed anfi resolved priortto the production date.
,f-A "
End forwarded message ^

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:: IJNCUA: aran lormat ror aocument requests 2. ot 2.

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