Extract to table

DEFINITIONS As used in these Requests for Production, the following terms shall have the meanings set forth below: 1

"AMA" or "DEFENDANT" shall mean Aurelius Media Americas Inc

"DOCUMENT" or "DOCUMENTS" shall have the broadest definition permitted under California Code of Civil Procedure section 2031

"COMMUNICATION" shall mean every manner or means of disclosure, transfer, or exchange of information, whether oral, written, or electronic, including but not limited to letters, emails, text messages, instant messages, telephone calls, voicemails, video calls, meetings, conversations, and social media interactions, and shall include both the content of the communication and any documents reflecting, summarizing, or memorializing such communication

"CLASS PERIOD" shall mean November 1, 2018 through the present, as alleged in the Consolidated Complaint filed in this action

"EMPLOYMENT PERIOD" shall mean the period of Plaintiff Fuentes's employment with AMA, specifically from March 14, 2019 through August 5, 2022, inclusive