Extract to table

As used in these Interrogatories and Requests for Production, the following terms shall have the meanings set forth below: 1

"Document" or "Documents" shall be given the broadest meaning permitted under Texas Rule of Civil Procedure 192

If any Interrogatory cannot be answered in full, Ridgeway shall answer to the fullest extent possible and shall state with specificity the reasons for its inability to provide a complete answer

If information is not available or not within Ridgeway's possession, custody, or control, Ridgeway shall so state and shall identify any person or entity believed to possess such information

If any Document or Communication responsive to these requests is withheld in whole or in part on the basis of attorney-client privilege, work product protection, or any other privilege, immunity, or objection, Ridgeway shall provide a privilege log in compliance with Texas Rule of Civil Procedure 193

Documents produced in response to these Requests shall be produced as they are kept in the usual course of business, or shall be organized and labeled to correspond with the categories in each Request for Production