In this morning's mail:
6. Identify all documents within the scope of this request for production which are not being produced and as to each document state the following information:
a. The basis of the non production;
b. The description of the document(s) not produced;
c. The identity of each and every person(s) who prepared the document(s);
d. The name and address of the person who presently has custody of the original and/or a copy of the document(s).
My response follows in the first comment to this post.