Contract analysis

1. Each Interrogatory shall be answered separately and fully under oath. Defendant shall restate each Interrogatory in full immediately before providing its answer thereto.

2. If Defendant objects to any Interrogatory or any part thereof, Defendant shall state with specificity the legal basis for each objection, including the particular grounds upon which the objection is based. Notwithstanding any objection, Defendant shall answer each Interrogatory to the fullest extent not foreclosed by the objection. A general or boilerplate objection without a specific legal basis shall not be deem

3. If the answer to any Interrogatory requires reference to or reliance upon documents, Defendant shall identify each such document by date, author, recipient(s), subject matter, document type, and Bates number (if produced), and shall state where the original of each such document may be found or inspected.

4. If Defendant claims any privilege, including but not limited to the attorney-client privilege, work-product doctrine, or any other protection, as to any information responsive to any Interrogatory, Defendant shall provide a privilege log in accordance with Florida Rule of Civil Procedure 1.280(b)(6), identifying for each withheld communication or document: (a) the date; (b) the author or sender; (c) each recipient

5. These Interrogatories shall be deemed continuing obligations pursuant to Florida Rule of Civil Procedure 1.280(e). Defendant must promptly supplement, amend, or correct its answers as additional responsive information becomes known to or available to Defendant.

6. The number of Interrogatories contained herein is twenty-five (25), which is within the limit permitted under Florida Rule of Civil Procedure 1.340(a). For purposes of computing the number of Interrogatories, each discrete subpart that is logically related to and in furtherance of the primary Interrogatory is not counted as a separate Interrogatory. INTERROGATORIES INTERROGATORY NO. 1: Entity Identification and Or