Following service upon it of plaintiff's notice for discovery and inspection containing 10 items, defendant Pacific Pool Industries, Inc. (defendant) complied with nine of the demands, but made no attempt to comply with demand number 10, which sought "[a]ll claims, correspondence, and legal pleadings received by the defendant relating to `Pacific-type' pools for the time of their first manufacture to date relating [to] allegations of defects in the design or construction...
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