Contract analysis

1. Full and Complete Responses. Pinnacle Atlantic shall respond to each interrogatory fully, separately, completely, and under oath within the time prescribed by the CPLR or, if applicable, within the time established by the arbitration panel. Each interrogatory shall be answered individually, and responses shall not incorporate by reference answers to other interrogatories except where expressly appropriate to avoid

2. Identification of Persons with Knowledge. Where an interrogatory calls for the identification of persons with knowledge, Pinnacle Atlantic shall identify all persons who participated in, contributed to, witnessed, or otherwise have knowledge of the relevant subject matter, regardless of whether such persons are current or former officers, directors, employees, agents, consultants, or representatives of Pinnacle At

3. Objections. If Pinnacle Atlantic objects to any interrogatory or any part thereof, Pinnacle Atlantic shall state the specific grounds for the objection with particularity and shall answer the interrogatory to the fullest extent not objectionable. A general or blanket objection shall not be deemed sufficient. An objection to any part of an interrogatory shall not be construed as an objection to any other part of th

4. Privilege Log. If any information responsive to these interrogatories is withheld in whole or in part on the grounds of attorney-client privilege, work product doctrine, or any other privilege or protection, Pinnacle Atlantic shall provide a privilege log identifying each withheld document or communication with sufficient specificity to enable QC&S and any tribunal to assess the applicability of the claimed privil

5. Continuing Obligation to Supplement. These interrogatories are continuing in nature. Pinnacle Atlantic is under a continuing obligation to supplement its responses promptly if additional, different, or corrective information becomes available after the initial responses are served, as required by CPLR § 3101(h) and any applicable arbitration rules or orders.

6. Subparts. Each subpart of an interrogatory that is lettered or numbered shall be treated as a separate interrogatory only to the extent required by applicable rules or court order. QC&S takes the position that subparts of an interrogatory that are logically related to a single topic constitute a single interrogatory for purposes of any numerical limitation on interrogatories.

7. Time Period. Unless otherwise specified, each interrogatory covers the period from July 1, 2019 (the effective date of the Treaty) through the date on which responses are served.

8. Construction. These interrogatories shall be construed broadly and liberally so as to require the fullest possible response. 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 interrogatory inclusive rather than exclusive. The term "including" shall mean "includi