Contract analysis

1. Attorney-Client Privilege and Work Product. AMA objects to each interrogatory to the extent it calls for information protected by the attorney-client privilege, the work product doctrine (Cal. Code Civ. Proc. § 2018.030), the joint defense privilege, or any other applicable privilege, immunity, or protection from disclosure recognized under California or federal law. No information subject to such protections will

2. Overbreadth and Undue Burden. AMA objects to each interrogatory to the extent it is overbroad in scope, unduly burdensome, oppressive, or seeks information that is not proportional to the needs of the case, considering the importance of the issues at stake, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of discovery in resolving the issues, a

3. Vagueness and Ambiguity. AMA objects to each interrogatory to the extent that it contains terms, phrases, or instructions that are vague, ambiguous, unintelligible, or otherwise susceptible to multiple reasonable interpretations. Where AMA has responded to an interrogatory notwithstanding this objection, AMA has done so based upon its reasonable interpretation of the interrogatory, and such response does not const

4. Compound, Conjunctive, and Disjunctive Interrogatories. AMA objects to each interrogatory that is compound, conjunctive, or disjunctive in nature, to the extent that such interrogatory exceeds the scope of a single interrogatory under California Code of Civil Procedure section 2030.060(f). AMA reserves the right to treat compound interrogatories as multiple interrogatories for purposes of the statutory limit.

5. Premature Class-Wide discovery. AMA objects to each interrogatory that seeks information about the experiences, claims, or circumstances of putative class members other than the named Plaintiffs, or that seeks class-wide data, on the ground that class certification has not been granted in this action, and such discovery is premature, disproportionate to the needs of the case at this stage of the proceedings, and c

6. Equally Available Information. AMA objects to each interrogatory to the extent it seeks information that is equally available to Plaintiffs through their own files, records, and recollections, through publicly available sources, or through third-party discovery that Plaintiffs can conduct directly.

7. Trade Secrets and Confidential Business Information. AMA objects to each interrogatory to the extent it calls for disclosure of trade secrets, proprietary business information, confidential financial data, or other competitively sensitive information. To the extent AMA produces or discloses any such information in response to these interrogatories, such production or disclosure shall be subject to and governed by

8. Incorporation by Reference. These General Objections are incorporated by reference into each and every specific response set forth below, as though fully restated therein. Where a specific response states that it is made "subject to and without waiving the foregoing objections" or words to similar effect, such statement is intended to preserve all General Objections and any specific objections set forth in the res

1. Facility 1 — 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069. This facility serves as AMA's corporate headquarters and primary post-production facility, housing executive offices, human resources, legal and compliance, finance, and post-production editorial suites.

2. Facility 2 — 4024 Penmark Strategy Partners Avenue, Studio City, California 91604. This facility houses Stage A and Stage B and serves as the primary production facility for AMA's unscripted programming division. Studio-based productions, including taping of competition and reality programming, are conducted at this facility.

3. Facility 3 — 15301 Ventura Boulevard, Suite 300, Sherman Oaks, California 91403. This facility serves as the production office and editing facility for AMA's digital content production division, which produces short-form content for streaming platforms and social media distribution.

4. Facility 4 — 3800 W. Alameda Avenue, Burbank, California 91505. This facility serves as the coordination center for AMA's live events and field production operations, including remote broadcast coordination, event logistics, and field production support.

5. Facility 5 — 1438 N. Gower Street, Hollywood, California 90028. This facility houses AMA's scripted development division, including writers' rooms, development offices, and a small post-production suite used for scripted pilot editing.

6. Facility 6 — 2120 Colorado Avenue, Santa Monica, California 90404. This facility serves as AMA's e-commerce studio, used for product integration content, branded entertainment production, and commercial content creation.

7. Facility 7 — 888 N. Sepulveda Boulevard, El Segundo, California 90245. This facility serves as a post-production annex, providing overflow editing and finishing capacity for projects originated at Facilities 1 and 5. Non-exempt, hourly employees were assigned to one or more of these facilities during the Class Period, depending on their job title, divisional assignment, and production schedule. Certain employees,

1. Employment Practices Liability Policy: Issued by Pemberton Mutual Assurance Co., Policy No. PMA-EPL-2022-00837, with a self-insured retention of $5,000,000 and an aggregate policy limit of $15,000,000.

2. Directors' and Officers' Liability Policy (Primary Layer): Issued by Redcliffe Specialty Insurance Ltd., Policy No. RSI-DO-2022-04419, with a policy limit of $10,000,000.

3. Directors' and Officers' Liability Policy (Excess Layer): Issued by Ashford Re Ltd., Policy No. ARL-EX-2022-01102, with a policy limit of $25,000,000. AMA tendered the claims asserted in this action to Pemberton Mutual Assurance Co. on November 8, 2022, promptly following the filing of the Fuentes Complaint. Pemberton acknowledged coverage under the EPL Policy, subject to a reservation of rights, by letter dated D