1) Plaintiff objects generally to each and every request in defendants requests for production to the extent that those

requests seek information protected from disclosure by the attorney-client privilege. No such documents or information will be produced. 2) Plaintiff objects generally to each and every request in defendants request for production to the extent that those requests seek information containing or reflecting the impressions, conclusions, opinions, legal research of theories of defendants attorneys case-preparation materials, or non-discoverable materials otherwise encompassed by the productions of the attorney work-prodct doctrine, or any other applicable statutory or common-law privilege. There, no such privileged documents or information will be produced. 3) Plaintiff objects generally to defendants requests for production to the extent that they seek to require disclosure of any confidential information. 4) Plaintiff objects generally to defendants requests for production to the extent that they seek to obtain information not within the possession, custody, or control of defendant. Such an attempt exceeds that scope of allowable discovery. 5) Plaintiff objects generally to instructions contained in defendants requests for production to the extent that they impose obligations greater than those imposed by the Oregon Rules Of Civil Procedure, or that they alter those obligations. 6) Plaintiff objects generally to defendants requests to the extent that the requests contained therein are vague, ambiguous, overly broad, unduly burdensome, or oppressive. 7) Plaintiff objects generally to each request for production to the extent that any request is duplicative or another, or seeks to obtain information, documents, or other materials previously provided by plaintiff to defendants or otherwise available to defendants or its counsel or seeks more than a single request. 8) Plaintiff objects generally to the terms employed in these requests for production to the extent that plaintiff understands them to call for plaintiff or its counsel to state legal conclusions. 9) Any statement that plaintiff will respond to any request contained in defendants requests for production does not constitute an admission by plaintiff that it agrees with the characterization or definition contained in such request. Futhermore,

any statement that plaintiff will produce any or all documents in response to any request for production does not constitute a representation or admission that plaintiff possesses such documents, or that such documents exisit al all. Rather it means that such documents will be produced or reviewed if any such documents are found in the course of a diligent search by defendant. 10) Plaintiff objects generally to each and every request in defendants request for production to the extent that they seek information not releveant to the subject matter of this action or reasonable calculated to lead to the discovery of admissible evidence as required by applicable rules.