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In addition, Backups should also be performed\u00a0before any core, plugin, or theme updates, as well as before installing new plugins.

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Please note that production should be made of any form in which such statements are held. Production is to be made to the undersigned counsel at 1011 Centre Road, Suite 210, Wilmington, DE 19805. All documents referred to or relied upon in Plaintiff's Answers to Interrogatories. All statements taken of any person relating to, referring to, mentioning or describing any of the facts of this case.

For example, if the statements a Case -cv-00032-SLR Document 11 Filed 04/22/2005 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CHRISTOPHER PAGE, JR. | | DONNIE KUKAN and | RED CLAY CONSOLIDATED SCHOOL | DISTRICT, | | Defendants. Please note that production should be made of any form in which such statements are held. DOC Case -cv-00032-SLR Document 11 Filed 04/22/2005 Page 2 of 4 recorded but not transcribed, such statements should be produced in their recorded form. Copies of all statements by the defendant(s), plaintiff(s), and other Copies of any and all writings which you intend to rely upon in any way at persons or witnesses relating to the incident in question or any other aspect of this litigation. Copies of all medical records and reports concerning the plaintiff's past, present or future physical condition or treatment. Copies of any and all writings in your possession or available to you in addition to the items specified in previous sections of this Request for Production which pertain in any way to the issues raised by the pleadings herein.

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