more

src/Constants/Copy/reqEditCopy.js

@@ -50,6 +50,10 @@ export const rogDefinitions = [
     id: "dda1376c-3d42-471f-9cb8-4a1ecb9c10cc",
     text: "“Document” means and includes all written and graphic matter of every kind and description, whether printed or produced by any mechanical, digital or other process, or by hand, whether final draft or reproduction, whether in the actual or constructive possession, custody or control of the respondent to a given interrogatory.  This includes any and all written letters, correspondence, memoranda, notes, statements, transcripts, files, charters, articles of incorporation, securities, bonds, stocks, certificates of deposit, evidences of debt, contracts, agreements, licenses, memoranda or notes of telephone or personal conversations, work papers, tapes, charts, reports, books, ledgers, telegrams, sound recordings, books of account, customer account statements, financial statements, catalogs, checks, check stubs, and written statements of witnesses or other persons having knowledge pertaining to the pertinent facts requested or relating to the interrogatory or subpart thereof, whether or not these documents are claimed to be privileged against disclosure.",
   },
+  {
+    id: "cc62a598-e50e-4e60-ae3a-9163dd73f8a5",
+    text: '“Describe" means a complete statement of all facts known to you about an incident, event, physical object, person, or other subject matter, together with any expert opinions about the subject matter, the basis for those opinions, and a description of all relevant documents and evidence that supports and/or refutes the fact or opinion.',
+  },
   {
     id: "05970162-1b13-4f98-ac73-91da0c8f0bf4",
     text: "“Identify” means, when used with reference to an individual person, organization, corporation or association, to state the full name, home and work addresses, e-mail address, home and business telephone numbers, present or last known position and business affiliation and position both in the past and at the time said interrogatory or subpart thereof is being responded to.",
@@ -59,8 +63,12 @@ export const rogDefinitions = [
     text: "The term “identify” further means, when used with reference to a document, to state the date it was created, its author, the signatory, if different, the addressee, the recipient of all copies, the type of document (e.g. chart, memorandum, letter, or other written document) and its present or last known custodian.",
   },
   {
-    id: "d800b745-6d55-44bb-b5e3-cd1f96516a2e",
-    text: "“Describe” means that the person or entity to whom the interrogatory or subpart thereof is directed should state what is requested to be described, including all facts and opinions known and held regarding, relating to, or pertinent to what is requested to be described, and (i) the identity of each person or entity involved or having any knowledge of each fact or opinion that relates to what is so described, (ii) the identity of each document evidencing the answer or response given or relating, referring or pertaining to said subject-matter in any way, and (iii) all relevant or material dates and time periods, specifying the way in which said dates or time periods are pertinent to the subject-matter described.",
+    id: "",
+    text: '"Refer to" or "refers to" means mentioning, discussing, making reference to or relating to in any way.',
+  },
+  {
+    id: "8ff2c80e-7dd8-4c48-b202-8702047c4946",
+    text: '"Relate(s) to" or "relating to" means constituting, defining, concerning, embodying, reflecting, identifying, stating, referring to, bearing upon, dealing with or in any way pertaining to.',
   },
 ];