Contract analysis

1. Each Interrogatory shall be answered separately and fully in accordance with Mass. R. Civ. P. 33. If any Interrogatory cannot be answered in full, Vantage shall answer to the fullest extent possible and shall state the specific reason(s) for any inability to provide a more complete answer, including but not limited to any ongoing investigation, unavailability of records, or other impediment to a complete response.

2. If Vantage objects to any Interrogatory or any part thereof, Vantage shall state with specificity the grounds for each objection. If an objection is made to only a part of an Interrogatory, Vantage shall answer the remaining, non-objectionable part of the Interrogatory fully and completely, and shall not use an objection to any portion of an Interrogatory as a basis for declining to respond to the Interrogatory in

3. If Vantage withholds any information responsive to any Interrogatory on the basis of a claim of attorney-client privilege, work-product protection, or any other privilege, Vantage shall, for each item of information withheld: (a) identify the privilege or protection claimed; (b) describe the nature of the information withheld in sufficient detail to permit Penterra and the Court to evaluate the claim of privilege,

4. These Interrogatories are deemed continuing obligations pursuant to Mass. R. Civ. P. 26(e). Vantage must seasonably supplement, amend, or correct its responses if it learns at any time that a prior response was incomplete, inaccurate, or incorrect, or if additional responsive information becomes available.

5. Where an Interrogatory calls for information within Vantage's "possession, custody, or control," such phrase shall be construed broadly and includes information known to, held by, or reasonably accessible to Vantage's officers, directors, members, managers, employees, agents, representatives, accountants, and attorneys (to the extent such information is not protected by a recognized privilege). Vantage shall make

6. All references to time periods in these Interrogatories are inclusive of the dates specified (i.e., references to a period "from" one date "to" another date include both the first and last dates identified). INTERROGATORIES INTERROGATORY NO. 1: Identification of Persons with Knowledge of the Territory Identify each Person who participated in, was present during, or has knowledge of the negotiation, drafting, revie