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Contract analysis / plaintiffs-first-interrogatories.docx
plaintiffs-first-interrogatories.docx
1013-00005 · 6 clauses
High · 0 Medium · 1 Standard · 0
1. Each interrogatory shall be answered separately and fully in writing under oath, pursua
1. Each interrogatory shall be answered separately and fully in writing under oath, pursuant to Fed. R. Civ. P. 33(b)(3), by an officer or agent of Helios who shall furnish such information as is available to Helios, including information held by its attorneys, agents, representatives, investigators, consultants, and all other persons acting on Helios's behalf.
2. Where Helios objects to any interrogatory or any part thereof, the objection must be st
2. Where Helios objects to any interrogatory or any part thereof, the objection must be stated with specificity, setting forth the grounds for the objection with sufficient particularity to permit the Court and GenomeDx to evaluate the merits of the objection. If Helios objects to any portion of an interrogatory, Helios must nevertheless answer the interrogatory to the extent the objection does not apply. A general o
3. If Helios elects to produce business records in lieu of answering any interrogatory pur
3. If Helios elects to produce business records in lieu of answering any interrogatory pursuant to Fed. R. Civ. P. 33(d), Helios must specify the records from which the answer may be derived or ascertained in sufficient detail to permit GenomeDx to locate and identify the responsive information as readily as Helios could, including the specific Bates numbers or document identifiers, custodian names, and file or folde
4. These interrogatories shall be construed to require all information within Defendant's
4. These interrogatories shall be construed to require all information within Defendant's possession, custody, or control, including information in the possession, custody, or control of Defendant's attorneys, agents, consultants, employees, accountants, investigators, or other representatives, whether or not such information is stored on Defendant's own systems or on third-party systems accessible to Defendant.
5. If any interrogatory cannot be answered in full after exercising due diligence, Helios
5. If any interrogatory cannot be answered in full after exercising due diligence, Helios shall answer to the fullest extent possible and shall provide a detailed explanation of why the remainder cannot be answered, including a description of the efforts undertaken to obtain the information and the specific reasons such information is unavailable.
6. The number of interrogatories contained herein complies with the limitations set forth Medium
⚑ Liability cap to check against exposure
6. The number of interrogatories contained herein complies with the limitations set forth in Fed. R. Civ. P. 33(a)(1), which permits a party to serve no more than twenty-five (25) interrogatories, including all discrete subparts. This set contains fifteen (15) interrogatories. GenomeDx reserves its right to propound additional interrogatories up to the limit permitted by the Federal Rules and the Court's Scheduling O