Contract analysis

1. Separate and Full Responses. Plaintiff is requested to respond to each interrogatory separately and fully in writing under oath, in accordance with California Code of Civil Procedure sections 2030.210 through 2030.240. Each response should be set forth immediately following the interrogatory to which it responds.

2. Time for Response. Responses are due within thirty (30) days of service of these interrogatories, pursuant to California Code of Civil Procedure section 2030.260. If these interrogatories are served electronically, the response deadline shall be extended by two (2) court days in accordance with California Code of Civil Procedure section 1010.6(a)(4)(B).

3. Inability to Respond Fully. If Plaintiff is unable to respond fully to any interrogatory after exercising due diligence to obtain the information necessary to respond, Plaintiff shall so state and shall set forth in detail the efforts made to obtain the information and the reasons why a complete response cannot be provided. In addition, Plaintiff shall identify all persons believed to have knowledge of the informa

4. Continuing Duty to Supplement. Pursuant to California Code of Civil Procedure section 2030.310, Plaintiff has a continuing duty to supplement, amend, or correct any response to these interrogatories if Plaintiff obtains further information or if a response was incorrect or incomplete when made. Any supplemental or amended response shall be served promptly upon discovery of additional or corrective information.

5. Objections. If Plaintiff objects to any interrogatory, Plaintiff shall state the specific grounds for each objection with particularity. If an objection is interposed to only a portion of an interrogatory, Plaintiff shall provide a response to the remainder of the interrogatory to the extent not subject to the objection. A general or boilerplate objection without specific factual and legal justification is insuffi

6. Protective Order. The parties have entered into a Stipulated Protective Order, which was filed with the Court and entered on February 15, 2023. Plaintiff may designate any response or portion thereof as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" in accordance with the terms of the Stipulated Protective Order, as appropriate. The existence of the Stipulated Protective Order does not relieve Plai

7. Scope. Unless otherwise stated, each interrogatory is intended to cover the time period from September 5, 2017 (the date of Plaintiff's Employment Agreement with AMA) to the date of Plaintiff's response to these interrogatories. Each interrogatory should be construed broadly and liberally, consistent with the broad scope of discovery under California Code of Civil Procedure section 2017.010. DEFINITIONS The follow