Extract to table

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

To the extent any Document contains both privileged and non-privileged information, non-privileged portions shall be produced and the redacted portions shall be identified on the privilege log

Documents shall be produced in the format specified in the Joint discovery Plan filed July 15, 2024 (D

To the extent Apex identifies additional responsive Documents after its initial response to these Requests, such Documents shall be produced promptly and no later than thirty (30) days after their identification

For each Request, Apex shall identify the custodian(s) and/or source(s) (including shared drives, databases, document management systems, and email accounts) from which responsive Documents were collected, and shall indicate if no responsive Documents were found for a particular custodian or source

If Apex objects to any Request or any portion thereof, Apex shall state the objection with specificity, including the factual and legal basis for each objection, and shall nonetheless produce all Documents that are responsive to the non-objectionable portions of the Request