Plaintiff's "triple threat" discovery to former employee stealing trade secrets

[Style of Case]

DEFINITIONS

1. As used herein, “____________” “you,” “your,” and “yours” shall refer to ____________.

2. As used herein, “the lawsuit” shall mean the lawsuit entitled “____________” filed in District Court in ____________ County.

3. As used herein, the term “documents” is used in the broadest sense of that term and includes, in addition to the material specifically designated hereafter, the original and all non-identical copies, whether different from the original by reason of notations made on such copies or otherwise, and all drafts of computer data, letters, telegrams, memoranda, reports of telephone conversations, ledgers, journals, invoices, bills, sales orders, call reports, financial and business records, receipts, contracts, reports, studies, calendar entries, diary entries, maps, pamphlets, notes, charts, forms, tabulations, analyses, statistical or informational accumulations, summaries or abstracts, any kind of records of meetings or conversations, firm impressions, sound or mechanical reproductions, rules, regulations, opinions, orders, interpretations, exceptions, position papers, guidelines, publications, instructions, transparencies, handbooks, manuals, operating procedures, appointment calendars, call slips, file jackets, course materials, training materials, minutes, testimony, press releases, speeches, surveys, graphs, statistics, tables, printed or typewritten forms (whether of visits, telephone calls, or otherwise) indices, agreements, graphic representations, cancelled checks, correspondence, memos, telephone message slips, sketches, notes of conversations, and all other written, printed, typed or other reported matter (including electronic or magnetic recordings), photographs, e-mails or other data compilations in which information can be obtained, which are in the possession, custody, or control of “you,” “your” attorneys, agents, physicians, directors, officers, partners, affiliates, subsidiaries, servants, or employees.

4. As used herein, “opposing attorney” shall mean (your name and address).

5. As used herein, “or” and “and” shall mean and/or.

6. As used herein, the singular shall include the plural, and the plural the singular, whenever the effect of doing so is to increase the information responsive to the request for information.

7. As used herein, “Plaintiffs” shall mean ____________ and ____________.

8. As used herein, “____________” shall mean ____________.

9. As used herein, “____________” shall mean ____________.

10. As used herein, “____________” shall mean ____________.

11. As used herein, “____________” shall mean ____________.

12. As used herein, “your attorneys” shall mean the attorneys hired to represent you in or consult with you about this lawsuit or the facts giving rise to this lawsuit.

13. As used herein, the term “communication” means any oral or written utterance, notation, or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, correspondence, conversations, dialogues, discussions, interviews, consultations, agreements, and other understandings between or among two or more persons.

14. As used herein, “propounding party(ies)” shall mean ____________ and ____________.

15. As used herein, “through the time of trial” shall mean from the number of years specified prior to the date this discovery was propounded through the time the parties in this lawsuit began conducting voir dire.

16. As used herein, “quality assurance” shall mean any and all efforts (including, but limited to, studies, tests, inspections, audits, examinations) and other activities conducted by or on behalf of you for the purpose of ascertaining whether or not food presentation, food preparation, customer service and your other operations are done safely, properly and conform to your mission statement, franchise agreement, objectives, policies, procedures and guidelines.

17. As used herein, “study” and “studies” shall mean any study made by or on behalf of you or any study made by some other person, firm, governmental entity, industry association or corporation including but not limited to, marketing analysis, focus groups, triads, diads, process and predictive analysis, tests, quality control analysis, interviews, mall intercepts, market research, surveys, questionnaires, attitude and usuage studies, awareness tracking, consumer interviews, segmentation studies, equity studies, corporate tracking, brand tracking, positioning studies, consumer pattern studies, mail surveys, AAUs, food studies, engineering analysis of hazards, (analysis of benefits, cost/benefit analysis, quality assurance analysis), development of policies and procedures, laboratory work, documentation of or summaries of any analysis, including similar situations.

18. As used herein, “test(s)” shall mean any tests made by or on behalf of you or tests made by some other person, firm, governmental entity, industry associations, or corporation, including but not limited to, experiments, static and dynamic tests, focus group testing, testing kitchens, copy testing, concepts testing, tasting tests, whether involving models or full-size components, computer simulated dynamic and static testing, computer assisted design, or computer animation.

19. As used herein “person” or “persons” means not only natural persons, but also corporations, partnerships, organizations, associations, industry groups, entities, joint venturers, corporations, natural persons, or any government or governmental entity, commission or agency and any divisions or departments or other units of any of the entities defined herein.

20. As used herein, “the rules” shall mean the (your state) Rules of Civil Procedure.

21. As used herein, “computer data” shall mean any documents, information or data ever placed into or stored on any of your computers, including but not limited to the hard drive, lap tops, disks, storage systems, retrieval systems and similar systems, e-mails, Internet transmissions, electronic bulletin boards, diary systems, calendar systems, tickler systems, and any other programs.

22. As used herein, “trade secret” or “trade secrets” shall mean any confidential data, lists, compilations, systems, material or information relating to any aspect of the business or operations of Plaintiffs, including but not limited to, any secret or confidential information relating to the business, customers, trade or industrial practices, policies, procedures, guidelines, forms, checklists, blueprints, trade secrets, technologies, recipes, systems, methods, confidential proprietary business methods, know how and similar information.

23. As used herein, “contact” means any personal or written communication, whether verbal, written, telephonic, via computer, via the Internet or through the use of any other communications medium.

24. As used herein, “governmental entity” shall mean any governmental organization, including but not limited to, any international, federal, state, regional, county, parish, city (whether incorporated, unincorporated or home rule) elective body, appointed body, legislative body, board, commission, agency, department, division, subdivision, and any other department or division of any of the previously listed entities.

25. As used herein, “industry group” and “industry groups” shall mean any association, company, corporation, trade group that includes in its membership companies or safety organizations, including but not limited to, Better Business Bureau (“BBB”), American National Standards Institute (“ANSI”), National Safety Council (“NSC”), National Restaurant Association, National Chamber of Commerce, any state restaurant association, Women’s Food Service Forum, International Occupational Safety & Health Information Center, National Institute for Occupational Safety & Health and The British Standards Institute.

26. As used herein, “Defendants” shall collectively mean ____________ and ____________.

27. As used herein, at “_____________” shall mean ____________.

    INSTRUCTIONS

1. If any or all documents...