Contract analysis

1. These interrogatories are propounded by Defendant Aurelius Media Americas Inc. ("AMA") to Plaintiff Marisol Fuentes ("Plaintiff") pursuant to California Code of Civil Procedure sections 2030.010 through 2030.090 and the Judicial Council Form Interrogatories (DISC-001). Plaintiff is required to answer each interrogatory fully, under oath, within thirty (30) days of service of these interrogatories, or within such o

2. Each interrogatory must be answered separately, fully, and completely, to the extent not objected to. If an objection is interposed to any interrogatory, the specific ground(s) for the objection must be clearly stated, and the interrogatory must nevertheless be answered to the extent that it is not objectionable.

3. If any interrogatory cannot be answered completely, Plaintiff shall answer it to the fullest extent possible, specifying the reason(s) why a complete answer cannot be given and stating whatever information or knowledge Plaintiff has regarding the unanswered portion of the interrogatory.

4. If a privilege is claimed as a basis for an objection, the objection must state the specific privilege invoked, the factual basis supporting the claim of privilege, and sufficient information to enable the Court to adjudicate the privilege claim, including the identity of the communicants, the date of the communication, the general subject matter of the communication, and the relationship of the communicants givin

5. These interrogatories are deemed to be continuing in nature pursuant to California Code of Civil Procedure section 2030.070. If, after serving responses to these interrogatories, Plaintiff obtains or discovers additional or different information responsive to any interrogatory, Plaintiff is obligated to serve supplemental responses as required by California Code of Civil Procedure section 2030.310.

6. Where an interrogatory requests identification of a DOCUMENT, Plaintiff shall state the title or description of the document, its date, the identity of its author(s), the identity of the addressee(s) or recipient(s), and the present location and custodian of the document. Where an interrogatory requests identification of a PERSON, Plaintiff shall state the person's full name, last known address, telephone number,

7. Where the response to an interrogatory incorporates or refers to a document, the document itself does not constitute a sufficient answer. Plaintiff must provide a narrative response that is complete in itself, without reference to or incorporation of documents or other responses, except as expressly permitted by California Code of Civil Procedure section 2030.230. Definitions. As used in these interrogatories, the