Contract analysis

1. Completeness of Response. If any Interrogatory cannot be answered in full, Ridgeway shall answer to the fullest extent possible and shall state with specificity the reasons for its inability to provide a complete answer. If information is not available or not within Ridgeway's possession, custody, or control, Ridgeway shall so state and shall identify any person or entity believed to possess such information.

2. Privilege Log. If any Document or Communication responsive to these requests is withheld in whole or in part on the basis of attorney-client privilege, work product protection, or any other privilege, immunity, or objection, Ridgeway shall provide a privilege log in compliance with Texas Rule of Civil Procedure 193.3. The privilege log shall identify, for each document or communication withheld: (a) the date of th

3. Organization of Production. Documents produced in response to these Requests shall be produced as they are kept in the usual course of business, or shall be organized and labeled to correspond with the categories in each Request for Production. To the extent that documents are produced in electronic form, they shall be produced in a format that is reasonably usable and that preserves existing metadata.

4. Lost or Destroyed Documents. If any Document or Communication responsive to these requests has been lost, destroyed, discarded, or is otherwise unavailable, Ridgeway shall identify the document or communication with as much specificity as possible and shall state: (a) the circumstances of its loss, destruction, or unavailability; (b) the date on which the document was lost or destroyed; (c) the identity of the per

5. Continuing Duty to Supplement. Ridgeway is reminded of its continuing duty under Texas Rule of Civil Procedure 193.5 to supplement and amend its responses to these Interrogatories and Requests for Production as additional or corrective information becomes available.

6. Time Period. Unless otherwise specified, each Interrogatory and Request for Production covers the Overcharge Period (February 1, 2019, through March 31, 2021) and extends through the date of Ridgeway's response to these discovery requests. INTERROGATORIES INTERROGATORY NO. 1: Identify by full name, title, job description, department, and dates of employment (including start date and, if applicable, end date) each