Sample Responses to Form Interrogatories for California

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Sample Responses to Form Interrogatories for California Powered By Docstoc
					1    Any Defendant
     Any Street
2    Any Town, CA 99999
     Telephone No.
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4    Defendant, In Pro Per
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6

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8                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
9                               IN AND FOR THE COUNTY OF XXX
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     NAME, a California Corporation,               )     CASE NO. XXX
11                                                 )
                                                   )
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                                 Defendant,        )
                                                   )     RESPONSES TO FORM
13   vs.                                           )     INTERROGATORIES, SET ONE
                                                   )
14   NAME, a California Corporation;               )
                                                   )
15                                                 )
                                 Defendants.       )
16                                                 )
                                                   )
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            PROPOUNDING PARTY: Plaintiff, NAME
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            RESPONDING PARTY : Defendant, NAME
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            SET NUMBER               : ONE
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22                   Pursuant to Code of Civil Procedure section 2030.010, Defendant hereby

23   responds to Defendant’s First Set of Form Interrogatories as follows:
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            It should be noted that this responding party has not fully completed investigation
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     of the facts relating to this case, and has not fully completed discovery in this action and
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     has not completed preparation for trial. All of the answers contained herein are based
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                                 RESPONSES TO FORM INTERROGATORIES
1    upon such information and documents which are presently available to or specifically
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     known to this responding party and disclose only those contentions which presently
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     occur to such responding party.
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            It is anticipated that further discovery, independent investigation, legal research
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6    and analysis will supply additional facts, add meaning to known facts, as well as

7    establishing entirely new factual conclusions and legal contentions, all of which may lead
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     to substantial additions to, changes in, and variations from the contentions herein set
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     forth. The following interrogatory responses are given without prejudice to responding
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     party’s right to produce evidence of any subsequently discovered fact or facts which this
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     responding party may later recall. Responding party accordingly reserves the right to

13   change any and all answers herein as additional facts are ascertained, analyses are
14   made, legal research is completed and contentions are made. The answers contained
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     herein are made in a good faith effort to supply as much factual information and as much
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     specification of legal contentions as is presently known which should in no way be to the
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     prejudice of defendant in relation to further discovery, research and/or analysis.

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20                                     GENERAL OBJECTION

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            Defendant has based these responses on the assumption that in propounding
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     these interrogatories, defendant does not seek materials protected against discovery by

24   (a) attorney/client privilege; (b) the attorney work product doctrine; (c) litigation privilege;
25   (d) constitutional or statutory right of privacy; (e) the confidentiality of statements or
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                                 RESPONSES TO FORM INTERROGATORIES
1    conduct made for settlement purposes; (f) trade secrets or other proprietary information
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     or privileges; or (g) materials which are irrelevant to the subject matter of this litigation.
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            Defendant objects to these interrogatories to the extent they seek materials not
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     relevant to the subject matter of this action or are not reasonably calculated to lead to
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6    the discovery of admissible evidence.

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            Defendant objects to these interrogatories to the extent they seek materials not
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     relevant to the subject matter of this action or are not reasonably calculated to lead to
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     the discovery of admissible eviden
				
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Description: These sample responses to form interrogatories for California are for use in an unlimited civil case ONLY. They can also be modified to respond to special interrogatories as well. The sample also contains a verification and proof of service by mail. The author is a freelance paralegal with over 14 years of experience in California civil litigation and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.
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