Contract analysis

1. Each interrogatory shall be answered separately and fully in writing under oath, in accordance with Federal Rule of Civil Procedure 33. Each answer shall restate the interrogatory to which it responds immediately preceding the answer.

2. If Plaintiff objects to any interrogatory or any part thereof, Plaintiff shall state the objection with specificity, including the legal and factual bases for the objection, and shall answer the interrogatory to the extent it is not objectionable. A general or boilerplate objection, without more, shall not be deemed a proper objection. An objection to part of an interrogatory does not excuse Plaintiff from answeri

3. If Plaintiff lacks sufficient information to answer any interrogatory fully, Plaintiff shall so state, describe the efforts made to obtain the information, and answer to the fullest extent of Plaintiff's current knowledge, information, and belief. Plaintiff may not refuse to answer an interrogatory simply because the answer is not fully known; Plaintiff must answer to the extent the information is available.

4. All answers must be supplemented or corrected in a timely manner in accordance with Federal Rule of Civil Procedure 26(e). If Plaintiff learns that a prior answer is incomplete or incorrect in any material respect, Plaintiff is obligated to serve supplemental or corrected answers promptly.

5. These interrogatories are continuing in nature. Plaintiff is under a continuing obligation to supplement answers if additional, corrective, or different information becomes known or available to Plaintiff after the initial responses are served.

6. Where an interrogatory calls for information over a period of time or asks Plaintiff to break down information by calendar year or other time period, Plaintiff shall provide the information broken down by the time periods requested. If Plaintiff cannot reasonably provide a breakdown by the time periods requested, Plaintiff shall provide the information for the entire Relevant Period and explain why a breakdown by

7. These interrogatories are deemed to include all subparts thereof. The subparts within each interrogatory are logically related and are part of a single interrogatory. Collectively, these interrogatories (Nos. 1–25) do not exceed the twenty-five (25) interrogatory limit prescribed by Federal Rule of Civil Procedure 33(a)(1) and Local Rule 33.2 of the Northern District of Texas.

8. If Plaintiff elects to produce business records in lieu of an answer pursuant to Federal Rule of Civil Procedure 33(d), Plaintiff shall specify the records from which the answer may be derived or ascertained and shall identify such records with sufficient detail and specificity to enable Defendant to locate, identify, and ascertain the answer as readily as Plaintiff could. A general reference to voluminous records