Extract to table

Each Interrogatory shall be answered separately and fully in writing, unless it is objected to, in which event the grounds for the objection shall be stated with specificity as required by Rule 33(b)(4)

If Defendant objects to any Interrogatory, in whole or in part, the specific grounds for each objection must be stated, and the Interrogatory must be answered to the extent it is not objectionable

Supplementation must be made in a timely manner and in no event later than the time required by Rule 26(e) or any scheduling order entered in this action

Whenever an Interrogatory asks Defendant to "identify" a document, Defendant shall provide: (a) the type or nature of the document (e

Whenever an Interrogatory asks Defendant to "describe" or "identify" a communication, Defendant shall state: (a) the date of the communication; (b) the form of the communication (i

To the extent any Interrogatory specifies a different time period, the time period stated in that Interrogatory shall govern