The following objections (the “general objections”) are applicable to every discovery request as though separately restate in response to each. Each response is subject to the general objections and will not include information covered by the general objections unless otherwise provided in that particular response. 1. Defendants object to the extent any discovery request fails to meet Rule 33. 2. Defendants object to the discovery requests insofar as they call for the disclosure of information protected by the attorney-client privilege, the work-product doctrine, or any other applicable statutory or common law privilege. The inadvertent production of any document disclosing any information subject to such privileges or protections is not intended to relinquish any privilege or protection and shall not be deemed to constitute a waiver of any applicable privilege or protection. 3. Defendants object to the discovery requests insofar as they are vague, ambiguous or unduly burdensome and/or seek information not relevant or material to the claims or defenses at issue in this matter or otherwise not reasonably calculated to lead to the discovery of admissible evidence. 4. Defendants object to the discovery requests to the extent they seek a response which is duplicative of responses to one or more of Plaintiff’s other discovery requests. 5. Defendants object to the discovery requests to the extent that they seek information publicly available to Plaintiff. 6. Defendant objects to the discovery requests to the extent that they are overbroad, including the requests that ask for the identification of all persons, all documents of a particular category or all facts and justifications. 7. As to each discovery request, Defendants do not warrant and expressly disclaims that its understanding of the terminology or phraseology used in the request is the same as Plaintiff’s intended meaning of such terminology or phraseology. 8. Defendants object to the identification of documents that are not in the exclusive possession, custody or control of Defendants or are not available to Defendants. 9. Defendants object to the discovery requests to the extent that they imply the existence of facts or circumstances which do not or did not exist, and to the extent that they state or assume legal conclusions. In providing these responses and objections to the discovery request, Defendants do not admit the factual or legal premise of any of the discovery requests or the Definitions or Instructions. 10. By submitting these responses, Defendants’ do not adopt Plaintiff’s purported definitions of words or phrases contained in the discovery requests. Defendants object to Plaintiff’s instructions and definitions contained in the discovery requests to the extent they are inconsistent with the ordinary and customary meaning of such words or phrases, the rules governing the permissible scope of discovery, or any definitions set forth by Defendants in their responses. 11. Defendants object to plaintiff’s instructions insofar as they vary from, purport to modify, enlarge upon, or are inconsistent with the Court Rules. Defendants object to the discovery requests to the extent the requests are unduly burdensome and expensive, unreasonably cumulative, or call for cumulative documents or information. 12. Defendants object to the discovery requests to the extent the requests are intended solely for the purpose of annoyance, embarrassment, harassment and oppression. 13. These general objections are incorporated into each and every response set forth below, and all such responses are subject to these objections. 14. Defendants’ to and without waiving their objections, Defendants respond as follows to the discovery requests:
Market Data 
Markets 
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