Contract analysis

1. AMA objects to each Request to the extent it seeks information or documents protected from disclosure by the attorney-client privilege, the work product doctrine, or any other applicable privilege or immunity from discovery. Any inadvertent production of privileged or protected materials shall not constitute a waiver of any privilege or protection, consistent with California Evidence Code § 912 and the terms of th

2. AMA objects to each Request to the extent it is overbroad, unduly burdensome, or seeks discovery that is disproportionate to the needs of the case in light of the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the pr

3. AMA objects to each Request to the extent it seeks trade secrets, proprietary business information, or commercially sensitive information beyond the scope of the Protective Order or the matters at issue in this litigation. AMA produces documents containing such information only to the extent required by applicable law and subject to the protections afforded by the Protective Order.

4. AMA objects to each Request to the extent it calls for the production of documents not within AMA's possession, custody, or control, including documents in the possession of third parties, affiliated entities, or former employees.

5. AMA reserves the right to supplement or amend these responses as additional information becomes available through ongoing investigation and discovery, including depositions, third-party discovery, and document review. AMA's responses are based upon the information and documents reasonably available to it as of the date hereof. SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 14 REQUEST FOR PRODUCTION NO. 14: Al