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For each interrogatory, request for admission or request for production to which the <br /> defendants object based on a claim that it is burdensome, the objection should state in detail the <br /> efforts needed to comply with the discovery request including,but not limited to: <br /> (1) The location and number of files and/or documents needed to be searched; <br /> (2) The location and number of persons needed to be interviewed; <br /> (3) The number of hours required for compliance; and <br /> (4) The estimated cost of compliance. <br /> Whenever you are asked herein to "state the basis" of a particular allegation, pleading, <br /> statement, belief, or contention, you must provide all of the following information with respect to <br /> each such allegation, pleading, statement, belief or contention: <br /> (1) state with particularity and in detail each and every fact, whether or not admissible as <br /> evidence, upon which said allegation,pleading, statement, belief or contention is based; <br /> (2) identify each person who has any knowledge, whether or not such knowledge <br /> constitutes admissible evidence, of facts which would in any reasonable manner tend to <br /> support said allegation, pleading, statement, belief or contention and state the basis for <br /> such knowledge. <br /> In responding to these interrogatories, requests for admissions, or requests for production <br /> please restate each interrrogatory, request for admission, or request for production immediately <br /> prior to your answer or response. <br /> 7 <br />