Contract analysis

1. Each interrogatory shall be answered separately and fully in writing under oath, as required by CPLR § 3133. Each answer shall restate the text of the interrogatory immediately preceding the response.

2. If any interrogatory cannot be answered in full after exercising due diligence, Meridian shall answer to the fullest extent possible, specify the portion of the interrogatory that cannot be answered, and state in detail the reasons for the inability to answer more fully, including any efforts undertaken to obtain the information.

3. If any interrogatory is objected to in whole or in part, Meridian shall state the specific grounds for the objection with particularity, and shall nevertheless provide the answer to the extent not objected to. A general or boilerplate objection that does not specify the grounds with particularity shall be deemed insufficient.

4. If any information called for by these Interrogatories is claimed to be protected by any privilege (including but not limited to the attorney-client privilege, the work-product doctrine, or any joint defense or common interest privilege), Meridian shall identify the privilege asserted, the factual basis for the privilege claim, and the nature of the information withheld, in a manner consistent with the requirement

5. These Interrogatories are continuing in nature. Meridian is obligated to supplement, correct, or amend its responses as additional or corrective information becomes known, pursuant to CPLR § 3101(h) and the ongoing duty of disclosure.

6. Where an interrogatory requests identification of all facts, documents, and witnesses relating to a particular subject, the response should be as comprehensive as reasonably possible and should not be limited by way of example or illustration. The phrase "including but not limited to," as used herein, shall not be construed to limit the scope of the interrogatory to the specific examples enumerated.

7. Unless otherwise specified in a particular interrogatory, the time period covered by these Interrogatories extends from January 1, 2019 through the date of Meridian's response.

8. The use of the singular form of any word shall include the plural, and vice versa. The use of any gender shall include all genders. The connective "and" shall be construed as both conjunctive and disjunctive, as necessary to make the interrogatory inclusive rather than exclusive. The connective "or" shall be construed in the same manner. INTERROGATORIES INTERROGATORY NO. 1 — Factual Basis for Count I (Wrongful Ter