Pursuant to Rule 33 of the Rules of Civil Procedure, answer the following written interrogatories pursuant to the following instructions and in accordance with the following definitions.
Rule 33(a) requires that each interrogatory must be answered separately and fully in writing under the penalties of perjury, unless it is objected to, in which event the reasons for the objection must be stated in lieu of the answer. Each answer or objection must be preceded by the interrogatory to which it responds. The answers must be signed by the person making them. Objections made to any interrogatory must be signed by the person or attorney making them. The party upon whom the interrogatories have been served must serve a copy of the answers and objections, if any, within 45 days after the service of the interrogatories, and must forthwith file the original answers.
2. In answering these interrogatories you are required to make full and complete answers. You must include in your answers all information that you know or that is available to you, including any and all information that you can obtain from (a) making inquiry of your principals, agents, employees, attorneys, representatives, assignors, other corporations directly under or in the penumbra of your parent corporation, any persons acting or purporting to act on your behalf, and any other persons in active concert and participation with you or with them, whether past or present and without regard to whether or not their relationship with you currently exists or has been terminated, and (b) making examination of any and all documents or tangible things in your possession, custody, or control that in any way refer or relate to the information sought by these interrogatories.
3. Each interrogatory is to be construed as asking for the source of any information provided in your answer thereto, including the identification of each person from whom you obtained any information provided in your answer and a description of any documents or tangible things relied upon by you in making your answer. Unless otherwise specifically so stated in your answer, your answer will be deemed a statement by you of your own knowledge.
4. If you sue or are sued in more than one capacity or if your answers would be different if suing or sued in any different capacity, such as an agent, assignor, assignee, delegor, delegee, or the like, then you are required to answer separately in each capacity.
5. You are required, if you object to any interrogatory on the grounds of privilege, work product, trade secret, or on any other grounds, to state for each such objection the precise nature of the objection made and a complete description of all facts, if any, upon which you or your counsel rely in making the objection.
6. Review each and every instruction of this set of instructions. When you have completed your answers to the interrogatories, if you have not complied fully and completely with any of the instructions, describe any instruction that you have not complied with and the grounds for such non-compliance.
7. YOU ARE SPECIFICALLY REQUESTED PURSUANT TO RULE 26(e)(3) TO SUPPLEMENT SEASONABLY ALL OF YOUR ANSWERS TO THESE INTERROGATORIES TO INCLUDE ANY INFORMATION ACQUIRED BY YOU AFTER THE DATE OF YOUR ANSWERS.
8. When a word is placed between quotation marks, it refers to the following definitions.
The term "document" is defined to be synonymous in meaning and equal in scope to the usage of this term in state-abbreviation.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. Thus, the term "document" is used in these interrogatories in its broadest sense and means any record of information of any kind or description, however made, produced, or reproduced, whether by hand or by any electronic, photographic, mechanical or other process. Documents can take the form of any medium on which information can be stored, including, without limitation, computer memory, motion pictures, photographs, film paper, phonograph records, tape recordings, videotapes, and video disks. The term "document" also includes all drafts, all originals, and all non-identical copies, whether different from the original by reason of any notation made on such copies or otherwise.
The terms "identify," "identity," "describe," or "description":
a. When used with respect to a natural person, shall mean the legal and any other name used by such person, his or her age, social security number, residential address, occupation, employer, business address, his or her job title and description of his or her duties, and name of the person's spouse.
b. When used with respect to a partnership, shall mean (i) the legal name of the partnership, (ii) all trade or other names under which the partnership does business, (iii) the name and residential address of each general and each limited partner of the partnership, (iv) the name of the jurisdiction in which the partnership is registered and of each state in which it is quali- fied to do business, (v) the addresses of all places of business maintained by such partnership, (vi) the place at which the business records of the partnership are maintained, and (vii) the name and business address of the keeper of the records of the partnership;
c. When used with respect to a corporation, shall mean (i) the legal name of the corporation, (ii) all trade or other names under which the corporation does business, (iii) the name and residential address of each officer and director of the corporation, (iv) the name and business address of each registered agent of the corporation, (v) the principal place of business of the corporation, (vi) the name of the jurisdiction in which it is incorporated, (vii) all states in which the corporation is legally qualified to conduct its business, (viii) the place at which the business records of the corporation are maintained, and (ix) the name and business address of the keeper of the records of the corporation.
d. When used with respect to a document, shall mean (i) its customary name or description and identifying number, if any, (ii) the date of the document, (iii) the identity of each person or entity who prepared the document, (iv) the identity of each person or entity who received the document or any copy thereof, (v) the identity of each person or entity who has possession, custody, or control of the document or any copy thereof.
e. When used with respect to a tangible thing, shall mean (i) its customary name or description and identifying number, if any, (ii) the date the tangible thing was made, produced, and, if you did not make or produce the tangible thing, the date you acquired it, (iii) the identity of each person or entity who made the tangible thing, (iv) the identity of each person or entity who has possession, custody, or control of the tangible thing or any copy thereof.
f. When used with respect to a communication, written or oral, means, if written, to identify the document or document in which it is contained; if oral, to state the date and to give the substance of the communications, to state whether it was by tele- phone or in person, and to state the place where it occurred, or in the case of a telephone communication, the location of each party to the conversation. For any communication which you contend is privileged or otherwise not subject to discovery, identification also means to state the basis for such contention and the grounds upon which an attorney-client privilege is claimed to identify the attorney and client, the bar of which the attorney is a member, to state whether the attorney is house counsel or outside counsel, to identify all persons present during the communication if oral, or who received a copy of the communication if written, and to identify all persons to whom the substance of the communication has been disclosed to at any time, in whole or in part.
The terms "you" and "yours," unless another intention clearly appears, refers to the party to whom these interrogatories are addressed, and to any of your principals, agents, employees, attorneys, representatives, insurers and any persons acting or purporting to act on your behalf, and any persons in active concert and participation with you, whether past or present, without regard to whether or not the relationship exists or has been terminated.
Okay? Eyes glazing over yet? Let's begin!
Oh, wait, don't tell me you actually read all that? No good lawyer would actually spend two seconds looking at all that boilerplate nonsense. Deduct 5 points. Sheesh.