Extract to table

Each interrogatory must be answered separately, fully, and completely, to the extent not objected to

If an objection is interposed to any interrogatory, the specific ground(s) for the objection must be clearly stated, and the interrogatory must nevertheless be answered to the extent that it is not objectionable

Where an interrogatory requests identification of a PERSON, Plaintiff shall state the person's full name, last known address, telephone number, and relationship to the parties or facts at issue

As used in these interrogatories, the following terms shall have the meanings set forth below: 1

"DOCUMENT" or "DOCUMENTS" shall have the broadest meaning ascribed to that term under California Code of Civil Procedure section 2016