Contract analysis

I. DEFINITIONS As used in these Interrogatories, the following terms shall have the meanings set forth below. These definitions are intended to be as broad and inclusive as permitted by the Florida Rules of Civil Procedure, and any ambiguity shall be construed in favor of producing a complete and responsive answer. 1. "You," "Your," or "Brecker" shall mean Randall Brecker, individually, and in his capacity as Managin

II. INSTRUCTIONS The following instructions apply to each and every Interrogatory contained herein: A. Each Interrogatory shall be answered separately and fully in writing and under oath, in conformity with Florida Rule of Civil Procedure 1.340. Your responses must set forth in full the answer to each Interrogatory, and each answer shall be preceded by the Interrogatory to which it is responsive. B. If You object to

I. If any responsive information is contained in business records maintained by any entity defined herein — including Coastal Palms, Suncoast, Gulf Breeze, Savannah Lodging, or any property-level entity — that is within Your possession, custody, or control (directly or by virtue of Your ownership, management, or officer position in such entity), You are obligated to obtain and produce such information in Your answers

III. INTERROGATORIES INTERROGATORY NO. 1 State Your full legal name, date of birth, current residential address, and all positions, titles, or roles You have held at any time during the Relevant Period with Coastal Palms Franchise Holdings LLC, Gulf Breeze Hospitality LLC, Savannah Lodging Partners LLC, Suncoast Room Management Inc., and any other entity involved in the ownership, operation, or management of the Hote