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(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 admission and requests for production, <br /> please restate each interrogatory, request for admission, or request for production immediately <br /> prior to your answer or response. <br /> If plaintiffs cannot answer any interrogatory or request in full, answer to the extent <br /> possible, explain why plaintiffs cannot answer the remainder, and state the nature of the <br /> information or knowledge that plaintiffs cannot answer. <br /> These interrogatories and requests are submitted for the purpose of discovery, and are not <br /> to be taken as waiving any objections which may be made at the trial to the introduction of <br /> evidence on subjects covered by these interrogatories and requests, or as an admission at the trial <br /> of the relevance or materiality of any of the matters covered by said interrogatories and requests. <br /> 7 <br />