Extract to table

Preservation of Objections The assertion of these General Objections is not intended to, and shall not, waive any specific objection set forth below

Likewise, the assertion of a specific objection in response to a particular Request is not intended to, and shall not, waive any General Objection

The production of documents in response to any Request shall not constitute an admission that such documents are relevant to, or admissible in, this action, nor shall it constitute a waiver of any objection, privilege, or defense

Nexford's use of any term defined by Plaintiff in these Responses shall not be construed as acceptance of Plaintiff's definition of that term for any other purpose

The production of documents in response to any Request shall not constitute a waiver of any objection, privilege, or defense, whether or not specifically asserted herein

Nexford further reserves the right to rely upon documents produced by Plaintiff or by third parties in support of its defenses and counterclaims, and the fact that Nexford has not produced a particular document in response to these Requests shall not be deemed a concession that the document is not relevant or supportive of Nexford's positions