Extract to table

DEFINITIONS As used in this Second Request for Production of Documents, the following terms shall have the meanings set forth below: 1

"Document" or "Documents" shall be defined as broadly as permitted under the Florida Rules of Civil Procedure, Rule 1

If, after serving its initial response, Ironclad obtains, discovers, or becomes aware of additional documents responsive to any of these requests, Ironclad must promptly supplement its responses and produce such additional documents in accordance with the Florida Rules of Civil Procedure

If any document responsive to these requests is withheld in whole or in part on the basis of any claim of privilege, attorney-client privilege, work-product protection, or any other legally recognized privilege or immunity from discovery, Ironclad must provide a privilege log identifying each such document with sufficient detail to permit Plaintiff and the Court to assess the validity of the claim

The privilege log shall be produced contemporaneously with Ironclad's document production

The term "including" means "including but not limited to" and shall not be construed as limiting the scope of any request