Contract analysis

1. Scope and Authority. These Interrogatories are propounded pursuant to JAMS Comprehensive Arbitration Rules and Procedures, Rule 17, and the Scheduling Order entered by the Arbitrator on May 15, 2023. MSH is required to respond to each Interrogatory fully, separately, and in writing, under oath, within thirty (30) days of service of these Interrogatories, or within such other time as may be ordered by the Arbitrato

2. Duty to Answer Fully. Each Interrogatory shall be answered separately, completely, and in good faith, based on all information reasonably available to MSH, including information in the possession, custody, or control of MSH's members, officers, managers, employees, agents, representatives, attorneys (to the extent not protected by privilege), and any other person acting on its behalf.

3. Continuing Obligation to Supplement. Each Interrogatory is continuing in nature. MSH is required to supplement its responses promptly if and when additional or corrective information becomes available, and in any event no later than thirty (30) days before the commencement of the arbitration hearing, or as otherwise ordered by the Arbitrator.

4. Partial Answers. If any Interrogatory cannot be answered in full, MSH shall answer to the extent possible and shall state with specificity the reason(s) why a complete answer cannot be provided, the efforts undertaken to obtain the information needed for a complete answer, and the identity of any person or entity believed to possess the information necessary for a complete response.

5. Objections. If MSH objects to any Interrogatory, MSH shall state the objection with particularity, specifying the grounds therefor, and shall nonetheless answer the Interrogatory to the extent not objectionable. A general or boilerplate objection, without a particularized explanation, shall be deemed insufficient. The assertion of an objection shall not relieve MSH of its obligation to provide all responsive infor

6. Privilege. If MSH withholds any information on the basis of attorney-client privilege, work-product protection, or any other privilege or immunity, MSH shall provide a privilege log in accordance with the Scheduling Order, identifying: (a) the date of the communication or document; (b) the author(s) and recipient(s); (c) the general subject matter; (d) the specific privilege or protection claimed; and (e) the fact

7. Verification. Responses to these Interrogatories must be verified under oath by a duly authorized representative of MSH having personal knowledge of the facts, or, where appropriate, by counsel on behalf of MSH as to matters within counsel's knowledge.

8. Defined Terms. All defined terms set forth in the Definitions section above shall apply throughout these Interrogatories. To the extent any term used herein is also defined in the Operating Agreement, the definition in the Operating Agreement shall control unless otherwise specified.

9. Time Period. Unless otherwise specified in an individual Interrogatory, each Interrogatory covers the period from June 15, 2017 (the effective date of the Operating Agreement) through the date of MSH's response.

10. Construction. These Interrogatories shall be construed broadly so as to elicit the maximum amount of information available. The terms "and" and "or" shall be construed disjunctively or conjunctively as necessary to make each Interrogatory inclusive rather than exclusive. The singular shall include the plural and vice versa. The use of a verb in any tense shall be construed as encompassing all tenses. INTERROGATOR