Contract analysis

1. Each Interrogatory shall be answered separately and fully in accordance with Rule 1.340, Florida Rules of Civil Procedure. Pinnacle shall provide all information within its possession, custody, or control, or that is otherwise available to it through reasonable inquiry of its officers, directors, employees, agents, representatives, adjusters, consultants, attorneys (to the extent not protected by applicable privil

2. If any Interrogatory cannot be answered in full after the exercise of due diligence and reasonable inquiry, Pinnacle shall answer to the fullest extent possible, specify the portion of the Interrogatory that cannot be answered, state the reason for the inability to provide a complete answer, and describe the efforts undertaken to obtain the requested information.

3. If Pinnacle objects to any Interrogatory or any part thereof, Pinnacle shall state the objection with specificity, identify the legal basis for the objection, and, notwithstanding the objection, answer the Interrogatory to the extent it is not subject to the stated objection. A general or blanket objection, without more, shall not be deemed a valid objection.

4. These Interrogatories are continuing in nature pursuant to Rule 1.280(e), Florida Rules of Civil Procedure. Pinnacle is required to supplement, amend, or correct its answers promptly upon obtaining additional or different information responsive to any Interrogatory.

5. Where an Interrogatory requests identification of a document, Pinnacle may, in lieu of providing the detailed identification information requested, specify the document by Bates number or other identifying designation and produce the document for inspection and copying pursuant to Rule 1.340(c), Florida Rules of Civil Procedure, provided that such production is made within the time period for answering these Inter

6. If any information responsive to any Interrogatory is withheld on the basis of the attorney-client privilege, the work-product doctrine, or any other applicable privilege or protection, Pinnacle shall provide a privilege log identifying for each item withheld: (a) the privilege or protection asserted; (b) the nature of the information or document withheld (e.g., memorandum, email, letter); (c) the date of the comm

7. If Pinnacle contends that any Interrogatory is vague, ambiguous, overly broad, or unduly burdensome, Pinnacle shall state its interpretation of the Interrogatory and respond accordingly, in addition to stating its specific objection. INTERROGATORIES INTERROGATORY NO. 1: Corporate Information and Organizational Structure State Pinnacle's full legal name, state of domicile, date of incorporation, principal office ad