First Set of Interrogatories to Defendant, 2012

NYC 9/11 Public Portal Document

Interrogatory, please provide all the information You are able to provide and state the reason for

Your inability to provide the remainder.

8. When an exact answer to an Interrogatory is not known, state the best estimate

available, state that it is an estimate, and state the basis for such estimate.

9. If documents responsive to any Interrogatory once in Your possession or under

Your control are requested or are the subject of an Interrogatory, and such documents are no

longer in Your possession or under Your control, state when such documents were most recently

in Your possession or under Your control, and what disposition was made of them, including

Identification of the person now in possession of or exercising control over such documents. If

the documents were destroyed, state when and where they were destroyed, and Identify the

person or persons who directed their destruction.

10. If You object to or otherwise decline to answer any portion of an Interrogatory,

please provide all information called for by that portion of the Interrogatory to which You do not

object or to which You do not decline to answer. For those portions of an Interrogatory to which

You object or to which You do not decline to answer, state the reason for such objection or

declination.

11. Every Interrogatory herein shall be deemed a continuing Interrogatory and

information in addition to or in any way inconsistent with Your initial answer to such

Interrogatory. The following Interrogatories shall be continuous until the date of the hearing.

and You must supplement Your answers as additional information becomes known or available

to You.

12. The time frame for each Request shall be August 27,2007 through the time of

trial, unless otherwise stated in the Request.

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NYC-WTC_000159152