(1) A party's duty to disclose documents is limited to documents which are or have been in the control of that party.
(2) For this purpose a party has or has had control of a document if —
(a) it is or was in the physical possession of the party;
(b) the party has or has had a right to inspect or take copies of it; or
(c) the party has or has had a right to possession of it.