Contract analysis

1. Each interrogatory must be answered separately and fully in writing and under oath, in accordance with CCP § 2030.210. Responses are due within thirty (30) days of service of these interrogatories, as provided by CCP § 2030.260.

2. Each interrogatory shall be answered to the fullest extent possible. If an interrogatory cannot be answered completely, it shall be answered to the extent possible, and the responding party shall state the reasons for her inability to answer the remainder. An interrogatory is not objectionable merely because it calls for an opinion, a contention, or the application of law to fact. See CCP § 2030.010(b).

3. If the responding party objects to any interrogatory, the specific grounds for such objection shall be clearly stated in accordance with CCP § 2030.240. If the objection applies to only part of the interrogatory, the responding party shall answer the non-objectionable portion of the interrogatory and clearly identify the specific part to which the objection is directed.

4. Pursuant to CCP § 2030.310, the responding party is under a continuing obligation to supplement, amend, or correct any response if the responding party subsequently obtains information rendering a prior response incomplete or incorrect. This continuing duty applies from the date of service of these interrogatories through and including the trial date in this matter.

5. In responding to these interrogatories, the responding party shall identify all persons who assisted in the preparation of the responses, including but not limited to attorneys, paralegals, consultants, and any other individuals who provided information or reviewed drafts of the responses.

6. If the responding party contends that any document or information responsive to an interrogatory is protected by the attorney-client privilege, the work product doctrine, or any other applicable privilege, the responding party shall provide a privilege log identifying each such document or item of information with sufficient specificity to permit assessment of the claimed privilege, including: (a) the date of the

7. Where an interrogatory asks the responding party to "state all facts" or "describe" certain events or circumstances, the responding party shall provide a complete and detailed narrative of the facts, circumstances, and events known to the responding party, including the identities of all persons with knowledge of the facts described and any documents that reflect, memorialize, or are relevant to such facts.

8. Unless otherwise specified, the time period covered by these interrogatories is the entirety of the responding party's employment with AMA and the period through the present date. DEFINITIONS As used in these interrogatories, the following terms shall have the meanings set forth below. These definitions are intended to supplement, not replace, any definitions provided by applicable statute or rule. "YOU," "YOUR,"