The full text of the definitions set forth in paragraph (c) of this rule is incorporated by reference into all discovery request, but shall not preclude:

1. the definition of other terms specific to the particular case;
2. the use of abbreviations; or
3. a narrower definition of a term defined in paragraph (c).

This rule does not broaden or narrow the scope of discovery permitted by the Federal Rules of Civil Procedure or these Local Rules.

The following definitions apply to all discovery requests:

1. "communication" means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise);
2. "document" is synonymous in meaning and equal in scope to the usage of this term in FR Civ P 34(a). A draft or non-identical copy is a separate document;
3. "identify" when referring to a person means to give, to the extent known, the person's full name and present or last known address. Once a person has been identified in accordance with this subparagraph, only the name of that person need be listed in response to subsequent discovery requesting the identification of that person;
4. "identify" when referring to documents means to give, to the extent known, the
   1. type of document,
   2. general subject matter,
   3. author(s), addressee(s), and recipient(s), and
   4. date the document was prepared;
5. "plaintiff," "defendant," a party's full or abbreviated name, or a pronoun referring to a party, mean the party, and, where applicable, its officers, directors, employees, and partners. This definition does not impose a discovery obligation on any person who is not a party to the case;
6. "person" means any natural person or any business, legal or governmental entity or association; and
7. "concerning" means referring to, describing, evidencing, or constituting.