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2. Scope.
(a) “Document” shall mean any writing, drawing, film, videotape,
chart, photograph, phonograph record, tape record, mechanical or electronic sound
recording or transcript thereof, retrievable data (whether carded, taped coded,
electrostatically or electromagnetically recorded, or otherwise), or other data
compilation from which information can be obtained, including (but not limited to)
notices, memoranda, diaries, minutes, purchase records, purchase invoices, market
data, correspondence, computer storage tapes, computer storage cards or disks,
books, journals, ledgers, statements, reports, invoices, bills, vouchers, worksheets,
jottings, notes, letters, abstracts, audits, charts, checks, diagrams, drafts,
recordings, instructions, lists, logs, orders, recitals, telegram messages, telephone
bills and logs, résumés, summaries, compilations, computations, and other formal
and informal writings or tangible preservations of information.
(b) This order pertains only to documents containing information
that may be relevant to, or may lead to the discovery of information relevant to:
i. any and all documents pertaining to Britney Spears,
Britney Touring, Inc., or any related entities of the “Britney Spears” brand
pertaining to or reflecting income generated by any negotiations, transactions,
sales, written and oral agreements (consummated, proposed, or in negotiation, i.e.,
amendments, revisions, modifications or riders thereto), statements regarding sub-
licensing, merchandising, and performing whether offered or solicited as they
relate to the accounting of Gross Receipts earned by Britney Spears, Britney
Touring, Inc. or any related entity owned or operated by Britney Spears between
January 1, 1999 through February 20, 2008.