Dm B3 Document Requests Fdr- Email From Dunne Re Draft Format For Document Requests 246

Mail:: INBOX: draft format for doc requests

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4.16MB / 476.84MB (0.87%) Date: Wed, 30 Apr 2003 15:07:15 -0400 From: [email protected] To: pzelikow@9-11 commission.gov 4f, [email protected] Cc: dmarcus® 9-11 commission.gov 9 Subject: draft format for doc requests Here's a draft format for document requests for your review and comment before we circulate it more widely among the staff: [Agency or Entity] DOCUMENT REQUEST No. XX The National Commission on Terrorist Attacks Upon the United States ("the Commission") requests that [the agency or entity] ("respondent") provide the Commission [alt: "authorized members of the Commission's staff"] with an opportunity to inspect [and copies of] the following documents no later than [production date] ("production date"): 1.

[specific document or class of documents]

2.

[specific document or class of documents]

3.

[etc.]

The term "documents" shall be interpreted broadly to mean written, recorded, and graphic materials of every kind in the repondent's possession, custody or control, including (without limitation) computer files, electronic mail, notes, drafts, and non-identical copies. The term "computer files" includes information stored in, or accessible through, computer or other information retrieval systems, translated, if necessary, by the respondent into reasonably useable form. The Commission requests that documents requested above be provided as soon as they are available, even though all requested documents may not be provided at the same time, through means of a "rolling" production. If any requested documents are withheld from production, even temporarily, based on an alleged claim of privilege or for any other reason, the Commission requests that the respondent, as soon as possible and in no event later than the production date, identify and describe each such document or class of documents, as well as the alleged basis for not producing it, with sufficient specificity to allow a meaningful challenge to any such withholding. If the respondent does not have possession, custody or control of any requested documents but has information about where such documents may be located, the Commission requests that the respondent provide such information as soon as possible and in no event later than the production date. If the respondent has any questions or concerns about the interpretation or scope of these document requests, the Commission requests that any such questions or concerns be raised as soon as possible so that any such issues can be addressed and resolved prior to the production date. [document requests to be sent to the agency or entity POC, with a cc: to Adam Ciongoli, DOJ, simultaneously]

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