Extract to table

Each interrogatory shall be answered in conformity with the requirements of those Rules and any applicable orders of this Court

Responses shall be served on counsel for Plaintiff at the address set forth in the signature block below

Where an interrogatory requests the identification of a person, Defendant shall provide the person's full legal name, current title or position, employer or business affiliation, and last known business address and telephone number

If any of this information is unknown to Defendant after the exercise of due diligence, Defendant shall so state and provide whatever partial information is available

If the document has not yet been produced, Defendant shall identify it with sufficient specificity to permit Plaintiff to request its production

If Defendant objects to any interrogatory, in whole or in part, Defendant shall state the objection with specificity, including the legal basis for the objection