Contract analysis

1. Responses to these Interrogatories are due within thirty (30) days after service, or within such other time as may be agreed upon by the parties or ordered by the Court, as provided by Code of Civil Procedure section 2030.260.

2. Each Interrogatory must be answered separately and fully, in writing, under oath. Pursuant to Code of Civil Procedure section 2030.210(a), each answer must be as complete and straightforward as the information reasonably available to the responding party permits.

3. If an Interrogatory cannot be answered completely, Plaintiff shall answer to the extent possible and state the reason(s) the remainder cannot be answered, as required by Code of Civil Procedure section 2030.220(b). An exercise of the option to respond to an Interrogatory by reference to records pursuant to Code of Civil Procedure section 2030.230 must comply with all requirements of that section, including a speci

4. If a claim of privilege or work product protection is asserted in response to any Interrogatory, Plaintiff must identify the specific privilege being claimed, the legal and factual basis for the claim, and sufficient information to permit AMA and the Court to evaluate the claim without disclosing the information claimed to be privileged. Such identification shall include, at a minimum, the nature of the informatio

5. All answers must reflect all information known or reasonably available to the responding party, including information that can be obtained through reasonable inquiry of Plaintiff's agents, representatives, attorneys, investigators, employees, consultants, and any other persons acting on Plaintiff's behalf, as required by Code of Civil Procedure section 2030.220(c).

6. If Plaintiff contends that additional information responsive to any Interrogatory will be obtained through further investigation or discovery, Plaintiff shall so state and shall supplement her responses in accordance with her ongoing obligations under the law.

7. Words used in the singular include the plural, and words used in the plural include the singular. Words used in the masculine gender include the feminine and neutral genders, and vice versa. The terms "and" and "or" shall be construed both conjunctively and disjunctively, as necessary, to make the Interrogatory inclusive rather than exclusive. The term "including" means "including but not limited to." Definitions.