2 - Assertions of Privilege. Generalized assertions of privilege will be rejected. A claim of privilege must be supported by a statement of particulars sufficient to enable the Court to assess its validity. For a more detailed discussion of the invocation of privilege, see Section V dealing with privilege. The procedures for invoking privilege set forth in Section V also apply to interrogatory answers.
3 - Interrogatory Responses. A party and counsel ordinarily have complied with their obligation to respond to interrogatories if they have:
(b) Conducted a reasonable inquiry, including a review of documents likely to have information necessary to respond to interrogatories;
(c) Objected specifically to objectionable interrogatories;
(d) Provided responsive answers; and,
(e) Submitted the answers under oath, signed by the appropriate party representative.
