Contract analysis

I. DEFINITIONS As used in these Interrogatories, the following terms shall have the meanings set forth below: 1. "You," "Your," "Defendant," or "Ironclad" shall mean Ironclad Indemnity Corporation (NAIC No. 20537), a Connecticut corporation, including its officers, directors, employees, agents, representatives, adjusters, underwriters, claims professionals, attorneys (to the extent not protected by the attorney-clien

II. INSTRUCTIONS The following general instructions apply to each Interrogatory set forth below: Instruction A — General. Each Interrogatory shall be answered separately and fully in writing, under oath, in accordance with Fla. R. Civ. P. 1.340. If Ironclad cannot answer any Interrogatory fully after exercising due diligence to obtain the information necessary to provide a complete answer, Ironclad shall so state and

III. INTERROGATORIES INTERROGATORY NO. 1 — Identification of Claims Personnel Identify each and every person employed by or acting on behalf of Ironclad who was involved in any way in the investigation, evaluation, adjustment, handling, review, or disposition of the Claim, including but not limited to claims adjusters, senior claims adjusters, claims managers, claims supervisors, claims directors, claims vice preside