There may be other documents responsive to this request that exists to which e.DIGITALis unaware of that at this time and/ or are in the exclusive possession or control of the parties / third parties to include but not limited to the defendant(Apple ) who has thus far not turned them over and / or produced them in discovery. There may be or are documents which the defendant( Apple ) has equal access to and / or exclusive control and / or possession of and / or other responsive documents in the control of unknown third parties of which e.DIGITALis unaware of at this time .e.DIGITAL has used its best efforts to obtain all responsive documents and make a timely disclosure thereof. Discovery is continuing at this time and e.DIGITAL reserve the right to supplement this response when / if more documents become available.
From Pacer document june ,2013 by Mr Handal
