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UNITED STATES DISTRICT COURT
[__________________] DISTRICT OF [__________________]

PLAINTIFF CORP.'S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT CORPORATION,

TO DEFENDANT CORPORATION, INC. AND ITS COUNSEL OF RECORD:

Pursuant to __________________ Plaintiff requests that Corporation answer the following special interrogatories separately and fully, in writing, and under penalty of perjury, within thirty (30) days after service.



DEFINITIONS AND INSTRUCTIONS

The following definitions apply to these document requests:

1. "PERSON" and/or INDIVIDUAL means, unless otherwise specified, any natural PERSON, firm, entity, corporation, partnership, proprietor ship, association, joint venture, other form of organization or arrangement, and government and government agency of every nature or type.

2. "CORPORATION" means CORPORATION, INC., and all predecessors, affiliates, managing agents, officers, and directors.

3. "YOU," "YOUR," and/or "CORPORATION" means DEFENDANT CORPORATION, INC., and any other PERSON representing it or acting on its behalf.

4. "PLAINTIFF" means Plaintiff Corp., and its directors, officers, parents, subsidiaries, predecessors, successors, assigns, agents, servants, employees, investigators, attorneys, and all other persons and entities representing it or acting on its behalf.

5. "ELECTRONIC STORAGE DEVICE" means any disk, including hard disks and floppy disks, CD-ROMs, DVDs, network servers, shared servers, computers, magnetic tape, back-up tape, voicemail, temporary files, and PDAs, whether currently on CORPORATION'S premises or other wise (e.g., at an employee's home or remote office).

6. "ELECTRONIC DATA" means any information, including files, documents, images, video, metadata or any combination thereof stored, created or used on ANY CORPORATION ELECTRONIC STORAGE DEVICE.

7. The term "EVIDENCE" or any variant thereof, including, but not limited to, the term "evidencing," when applied to the content of any document, shall be understood to apply if the document directly or indirectly mentions, discusses, constitutes, concerns, supports, contradicts, refers to or in any other way deals with the subject matter described in the Request in which the term appears.

8. "AND" and "or" have both conjunctive and disjunctive meanings; "all" and "any" means both "each" and "every"; the plural shall include the singular and vice versa.

9. "ANY" shall be understood to include and encompass "all." As used herein, the singular shall always include the plural and the present tense shall also include the past tense. The words "and" as well as "or" shall be construed disjunctively or conjunctively as necessary to bring within the scope of this request all DOCUMENTS or things that might otherwise be construed to be outside its scope.

10. To "IDENTIFY" a DOCUMENT means (a) to refer to the DOCUMENT'S identification or exhibit number if the DOCUMENT has been 5 previously produced or used in discovery; or (b) to state the DOCUMENT'S title, authors, recipients, and date of creation.

If you object to any of the interrogatories, state the grounds for the objection(s). If you object to only part of an interrogatory, state the objection and answer the remainder of the interrogatory.

INTERROGATORY NO. 1

Describe every policy implemented by YOU to retain ELECTRONIC DATA.

INTERROGATORY NO. 2

Describe every policy implemented by YOU to destroy ELECTRONIC DATA.

INTERROGATORY NO. 3

Describe in detail CORPORATION'S use and maintenance of its ELECTRONIC STORAGE DEVICES including any vendors used for cloud storage.

INTERROGATORY NO. 4

IDENTIFY ALL ELECTRONIC DATA CORPORATION destroyed, altered or moved, including timing and circumstances of such destruction, alteration, or movement.

INTERROGATORY NO. 5

IDENTIFY ALL individuals responsible for implementation of any policies RELATED to storage and/or retention of DOCUMENTS.

Respectfully submitted,

____________________[firm name]

By: __________________[signature]

__________________[typed name]

__________________[address]

______[area code, phone no.]

_______[______Bar no.]

Attorney for __________________[party designation]