Extract to table

Each Interrogatory must be answered separately and fully, in writing, under oath

210(a), each answer must be as complete and straightforward as the information reasonably available to the responding party permits

If an Interrogatory cannot be answered completely, Plaintiff shall answer to the extent possible and state the reason(s) the remainder cannot be answered, as required by Code of Civil Procedure section 2030

If Plaintiff contends that additional information responsive to any Interrogatory will be obtained through further investigation or discovery, Plaintiff shall so state and shall supplement her responses in accordance with her ongoing obligations under the law

The terms "and" and "or" shall be construed both conjunctively and disjunctively, as necessary, to make the Interrogatory inclusive rather than exclusive

As used in these Interrogatories, the following terms shall have the meanings specified below: 1