Contract analysis

1. These Interrogatories are to be answered separately, fully, and under oath by an officer or agent of Vantor Holdings Corp. having knowledge of the facts, pursuant to CPLR § 3133. Answers shall be based upon all information within the knowledge, possession, custody, or control of Vantor, including information known to or in the possession of Vantor's officers, directors, employees, agents, representatives, attorney

2. Each Interrogatory is deemed continuing in nature pursuant to CPLR § 3101(h). Vantor is required to supplement, amend, or correct its answers promptly as additional or corrective information becomes available, and to serve such supplemental answers upon Plaintiff's counsel without awaiting a further request.

3. If any Interrogatory cannot be answered in full, Vantor shall answer to the fullest extent possible and shall explain with specificity why the answer is incomplete. In providing such explanation, Vantor shall identify any Documents or Persons that would enable a more complete answer and shall describe the efforts undertaken to obtain the necessary information.

4. If Vantor objects to any Interrogatory, in whole or in part, Vantor shall state the objection with specificity and shall nonetheless answer the Interrogatory to the extent not subject to the objection. General or boilerplate objections without a specific factual basis are insufficient and shall be deemed waived.

5. If Vantor claims any privilege, work-product protection, or other protection from disclosure in response to any Interrogatory, Vantor shall provide a privilege log entry for each response or portion thereof withheld on the basis of such claim. Each privilege log entry shall include, at a minimum: (a) the nature of the privilege or protection asserted; (b) the date of the withheld information or Communication; (c)

6. Where an Interrogatory seeks the identification of Persons, Vantor shall provide the requested information for all Persons who have knowledge relevant to the subject matter of the Interrogatory, including former employees, former agents, and former contractors of Vantor, regardless of whether such Persons are currently employed by or affiliated with Vantor.

7. The defined terms set forth in the Definitions section above are incorporated into each Interrogatory. The use of defined terms is not intended to narrow the scope of any request; where a defined term is used, it is intended as a convenient shorthand and shall be construed broadly and in accordance with the definition provided.

8. These Interrogatories are addressed to Vantor Holdings Corp. and shall be answered by officers or agents of Vantor having knowledge of the facts sought, including but not limited to: Raymond Kettler (Chief Executive Officer and Chairman), Susan Hargrove (President and Chief Operating Officer), Nathan Orris (Senior Vice President, Valuation Services), Deepa Rajaram (Vice President, Client Valuation Operations), and

9. Unless otherwise specified, the time period covered by each Interrogatory is the Relevant Period (Q1 2021 through Q3 2023). Where an Interrogatory expressly specifies a different or broader time period, that specification shall control.

10. The singular form of any word shall include the plural, and the plural shall include the singular. The terms "and" and "or" shall be construed both conjunctively and disjunctively so as to bring within the scope of each Interrogatory all information that might otherwise be construed to fall outside its scope. INTERROGATORIES INTERROGATORY NO. 1: Identification of All Vantor Personnel Involved in Ironside Valuatio