Contract analysis

1. Each interrogatory herein shall be answered separately and fully, in writing and under oath, in compliance with California Code of Civil Procedure sections 2030.210 through 2030.310. Each response shall set forth as much information as is presently known to the responding party or is reasonably available to the responding party upon reasonable inquiry.

2. If any interrogatory cannot be answered in full after the exercise of due diligence, it shall be answered to the extent possible, and the responding party shall specify the reason for the inability to answer the remainder of the interrogatory, including a statement of whatever information or knowledge the responding party has concerning the unanswered portion.

3. If any interrogatory is objected to, the objection shall be stated with specificity, including the legal basis for the objection. Notwithstanding any objection, the responding party shall respond to the non-objectionable portion of the interrogatory to the fullest extent possible. A general or boilerplate objection, without more, is insufficient and does not excuse the responding party from the obligation to provi

4. The responding party is under a continuing obligation to supplement or amend any response to the extent that the responding party obtains additional or different information after serving the initial response. This obligation continues throughout the pendency of this action.

5. In responding to each interrogatory, the responding party shall identify all sources of information upon which the response is based, including the identity of any person who provided information used in formulating the response and the identity of any document reviewed or consulted in connection with the response.

6. If any information responsive to an interrogatory is withheld on the basis of a claim of privilege or work product protection, the responding party shall identify the specific privilege claimed, the nature of the information withheld, and the factual basis for the claim of privilege with sufficient specificity to permit the propounding party to evaluate the claim, including: (a) the type of information withheld (e

7. Words used in the singular shall include the plural, and words used in the plural shall include the singular. Words used in the masculine gender shall include the feminine and neutral genders, and vice versa. The connective "and" shall be construed as both conjunctive and disjunctive, and the connective "or" shall be construed as both disjunctive and conjunctive, so as to bring within the scope of each interrogato

8. The terms "any" and "all" shall be construed broadly and shall mean "each and every." DEFINITIONS As used in these interrogatories, the following definitions shall apply: A. "YOU," "YOUR," "PLAINTIFF," or "HALLORAN" refers to Derek Halloran, individually, including anyone acting on his behalf, and encompasses Halloran's knowledge, information, and belief, as well as information available to him upon reasonable inq

I. "MEAL PERIOD" refers to a meal period as defined under California Labor Code section 512 and Industrial Welfare Commission ("IWC") Wage Order 12-2001 (the Motion Picture Industry Order), section 11, including the requirement that an employer may not employ an employee for a work period of more than five (5) hours per day without providing the employee with a meal period of not less than thirty (30) minutes, during