Contract analysis

1. Each interrogatory shall be answered separately and fully in writing, under oath, and the answer shall restate the text of the interrogatory preceding the response.

2. If Northwind objects to any interrogatory or any part thereof, Northwind shall state the specific grounds for the objection with particularity and shall answer the interrogatory to the extent not objected to. A general or blanket objection, without more, is insufficient.

3. If any interrogatory cannot be answered in full after the exercise of due diligence, Northwind shall answer to the extent possible, specifying the reasons why a complete answer cannot be provided, and stating whatever information or knowledge is presently available to Northwind. If the information is in the possession, custody, or control of a third party, Northwind shall so state and identify the third party.

4. Where an interrogatory requests information for a specific time period, Northwind shall respond for the entire period unless the interrogatory otherwise specifies a different temporal scope.

5. These interrogatories are deemed to include all sub-parts as a single interrogatory where the sub-parts relate to a common topic, consistent with the CPLR and applicable Commercial Division rules. Defendants reserve the right to serve additional interrogatories as permitted by law and any scheduling orders entered in this action.

6. If Northwind contends that any information sought is protected by the attorney-client privilege, the work-product doctrine, or any other privilege or protection, Northwind shall provide a privilege log identifying each withheld document or communication with sufficient detail to permit Defendants and the Court to assess the claim of privilege, including the date, author, recipient(s), subject matter, and the speci

7. Unless otherwise indicated, each interrogatory relates to the period from January 1, 2020 through the date of Northwind's response. INTERROGATORIES INTERROGATORY NO. 1 — Corporate Identity and Authority Identify all officers, directors, and managing agents of Northwind Maritime Corporation as of the date of execution of the Charter-Party (December 3, 2020) and as of the date of filing of the Complaint (October 2,