Contract analysis

1. Continuing Obligation. These requests are continuing in nature pursuant to Florida Rule of Civil Procedure 1.280(e). If, after serving its initial response, Ironclad obtains, discovers, or becomes aware of additional documents responsive to any of these requests, Ironclad must promptly supplement its responses and produce such additional documents in accordance with the Florida Rules of Civil Procedure.

2. Organization of Production. Documents should be produced as they are kept in the usual course of business, or organized and labeled to correspond to the categories in each numbered request. Where documents are produced electronically, they should be produced in their native format or as single-page TIFF images with associated extracted text and metadata load files, Bates-numbered sequentially, and accompanied by a

3. Privilege Log. If any document responsive to these requests is withheld in whole or in part on the basis of any claim of privilege, attorney-client privilege, work-product protection, or any other legally recognized privilege or immunity from discovery, Ironclad must provide a privilege log identifying each such document with sufficient detail to permit Plaintiff and the Court to assess the validity of the claim.

4. Lost or Destroyed Documents. If any document responsive to these requests has been lost, destroyed, discarded, deleted, overwritten, or is otherwise no longer in Ironclad's possession, custody, or control, Ironclad shall: (a) identify the document by description, date, author, and recipient(s) to the best of its knowledge; (b) describe the document's contents and subject matter; (c) state the date and circumstance

5. Possession, Custody, or Control. These requests are directed to all documents in Ironclad's possession, custody, or control, regardless of the physical or electronic location of such documents. Documents shall be deemed to be within Ironclad's possession, custody, or control if Ironclad has the legal right or practical ability to obtain the documents, including documents held by Ironclad's agents, representatives,

6. Construction. The use of the singular includes the plural, and vice versa. The use of any gender includes all genders. The terms "and" and "or" shall be construed conjunctively or disjunctively as necessary to make the request inclusive rather than exclusive, so as to bring within the scope of the request all responses that might otherwise be construed to be outside its scope. The use of the present tense includes