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Contract analysis / cascade-responses-first-interrogatories.docx
cascade-responses-first-interrogatories.docx
High · 1
Medium · 0
Standard · 0
1. Cascade objects to each and every interrogatory to the extent it seeks information or d
1. Cascade objects to each and every interrogatory to the extent it seeks information or documents protected by the attorney-client privilege, the attorney work product doctrine (whether opinion or fact work product), the joint defense and common interest privilege, or any other applicable privilege, protection, or immunity from discovery recognized under California law or federal law. No response herein shall be con
2. Cascade objects to each and every interrogatory to the extent it is vague, ambiguous, o
2. Cascade objects to each and every interrogatory to the extent it is vague, ambiguous, overbroad, unduly burdensome, oppressive, or not reasonably calculated to lead to the discovery of admissible evidence. Cascade further objects to each interrogatory to the extent it seeks information that is not relevant to the subject matter of this action or to the claims and defenses of the parties.
3. Cascade objects to any interrogatory that seeks to impose upon Cascade obligations beyo
3. Cascade objects to any interrogatory that seeks to impose upon Cascade obligations beyond those required by the California Code of Civil Procedure, Sections 2030.010 et seq., or that is otherwise inconsistent with the scope of permissible discovery under California law.
4. Cascade objects to any interrogatory that is compound, conjunctive, or disjunctive in a
4. Cascade objects to any interrogatory that is compound, conjunctive, or disjunctive in a manner that effectively constitutes multiple discrete interrogatories in violation of the statutory limit on the number of interrogatories that may be propounded without leave of court, as set forth in California Code of Civil Procedure Section 2030.030.
5. Cascade objects to each and every interrogatory to the extent it calls for a legal conc
5. Cascade objects to each and every interrogatory to the extent it calls for a legal conclusion, asks Cascade to interpret or construe documents or agreements, or seeks the mental impressions, conclusions, opinions, or legal theories of Cascade's counsel.
6. Subject to and without waiving these General Objections, and subject to and without wai
High
⚑ Non-compete / exclusivity restraint
6. Subject to and without waiving these General Objections, and subject to and without waiving any specific objection asserted below, Cascade responds to the individual interrogatories as follows. INTERROGATORY NO. 1 INTERROGATORY: Identify all persons who participated in the planning, development, or implementation of the initiative known as "Project Atlas," including each person's title, role within the initiative,