Contract analysis

I. DEFINITIONS As used in these Interrogatories and Requests for Production, the following terms shall have the meanings set forth below: 1. "You," "Your," "Ridgemark," or "Plaintiff" shall mean Ridgemark Development Partners LLC, a Florida limited liability company, including its members Hector J. Vilanova and Claudia R. Vilanova, its managers, officers, employees, agents, representatives, attorneys (except as limit

1. Each interrogatory and each request for production shall be answered separately and fully. Ridgemark shall restate each interrogatory or request immediately before providing its response thereto.

2. If any interrogatory or request for production cannot be answered or responded to in full, Ridgemark shall answer or respond to the extent possible, specify the reason why a complete answer or response cannot be given, and state what efforts have been made to obtain the information necessary to provide a complete answer or response.

3. If Ridgemark objects to any interrogatory or request for production, Ridgemark shall state the specific grounds for the objection with particularity and shall nonetheless answer the interrogatory or produce documents to the extent not covered by the objection. A general or blanket objection is insufficient and shall not excuse Ridgemark from responding to the non-objectionable portions of any interrogatory or requ

4. If Ridgemark withholds any document or information on the basis of any privilege, including the attorney-client privilege, or on the basis of work-product protection, Ridgemark shall provide a privilege log in compliance with Florida Rule of Civil Procedure 1.280(b)(6), identifying each withheld document by: (a) the date of the document; (b) the author or sender; (c) all recipients, including those who received co

5. Documents shall be produced as they are kept in the ordinary course of business, or alternatively, shall be organized and labeled to correspond with the categories in the requests for production. If documents are produced in electronic form, they shall be produced in a reasonably usable format that preserves metadata.

6. If any responsive document has been lost, destroyed, discarded, or is no longer in Ridgemark's possession, custody, or control, Ridgemark shall: (a) identify each such document to the best of its ability; (b) describe its contents; (c) state when it was lost, destroyed, or discarded, and by whom; (d) state the reason for its loss, destruction, or disposal; and (e) identify any person known or believed to possess a

7. These interrogatories and requests for production are intended to be continuing in nature. Ridgemark is required to supplement, amend, or correct its responses in a timely manner if it obtains additional or corrective information after the date of its initial responses, in accordance with Florida Rule of Civil Procedure 1.280(e).

III. INTERROGATORIES INTERROGATORY NO. 1 — Identification of Ridgemark's Members and Management Identify all current and former members, managers, and officers of Ridgemark Development Partners LLC from the date of its formation to the present, and for each such person state: (a) their full legal name; (b) their ownership percentage or membership interest in Ridgemark; (c) the dates during which they held such member

IV. REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1 — Deed Conveying the Southern Parcel to Ridgemark Produce the deed or deeds by which Ridgemark acquired the Southern Parcel (Seminole County Parcel ID 25-20-30-500-0030-0000) from the Estate of Roland P. Thurmond, including any exhibits, attachments, legal descriptions, and affidavits appended thereto. This request includes but is not limited to the special war