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IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI
PLAINTIFF
VS. CIVIL ACTION NO.
DEFENDANTS
DEFENDANTS RESPONSES AND OBJECTIONS TO PLAINTIFF'S
FIRST SET OF INTERROGATORIES
COMES NOW, Defendants, and , by and through their
attorney of record, in responding to Plaintiff's First Set of Interrogatories, and states as follows:
INTERROGATORY NO. 1 : Please state the full name and address of each person
supplying information and/or answering these interrogatories.
RESPONSE TO INTERROGATORY NO. 1 :
INTERROGATORY NO. 2 : Please state the name, address and telephone number of
each and every person you intend calling as a witness at the trial of this cause.
RESPONSE TO INTERROGATORY NO. 2 :
INTERROGATORY NO. 3 : Identify each expert you intend to call as an expert witness
at the trial of this cause, and state the subject matter upon which he or she is expected to testify,
Page 1 of 7
the substance of the facts, and a summary of the grounds for each opinion.
RESPONSE TO INTERROGATORY NO. 3 :
INTERROGATORY NO. 4 : Please state the name, address, telephone number and
relationship to Defendants of every person who may have knowledge of the facts complained of
in this proceeding.
RESPONSE TO INTERROGATORY NO. 4 :
INTERROGATORY NO. 5 : Identify all experts and/or consultants from whom you have
obtained any opinion concerning any matter involved in this litigation and describe the
purpose(s) for which each such expert or consultant was retained or specially employed.
RESPONSE TO INTERROGATORY NO. 5 :
INTERROGATORY NO. 6 : Identify each document, which you intend to offer into
evidence at trial.
RESPONSE TO INTERROGATORY NO. 6 :
Page 2 of 7
INTERROGATORY NO. 7 : What was the net worth of on ,
and on , .
RESPONSE TO INTERROGATORY NO. 7 :
INTERROGATORY NO. 8 : Please explain the basis for the values given in your answer
to interrogatory number 7 above. Also, identify each and every document or financial record,
which supports your answer.
RESPONSE TO INTERROGATORY NO. 8 :
INTERROGATORY NO. 9 : Explain in detail the consideration paid by in
exchange for the issuance of 510 shares of common stock of in his/her name.
RESPONSE TO INTERROGATORY NO. 9 :
INTERROGATORY NO. 10 : Explain in detail the consideration paid by in
exchange for the issuance of shares of common stock of in his/her name.
RESPONSE TO INTERROGATORY NO. 10 :
Page 3 of 7
INTERROGATORY NO. 11 : Identify the compensation received by from
each month from , through , .
RESPONSE INTERROGATORY NO. 11 :
INTERROGATORY NO. 12 : Identify the compensation received by from
each month from , through , .
RESPONSE TO INTERROGATORY NO. 12 :
INTERROGATORY NO. 13 : Explain in detail the reasons was terminated as an
employee of on or about , .
RESPONSE TO INTERROGATORY NO. 13 :
Page 4 of 7
THIS, the day of , 20 .
Respectfully submitted,
____________________________________________
____________________________________________
AS TO OBJECTIONS:
___________________________________________
CERTIFICATE OF SERVICE
This is to certify that I, , counsel for defendants,
have mailed this day by U.S. Mail, postage prepaid, and transmitted via facsimile, a true and
correct copy of the above and foregoing to , Attorney for
Plaintiff, at and facsimile number .
This the day of , .
_____________________________________
Page 5 of 7
STATE OF MISSISSIPPI
COUNTY OF
PERSONALLY came and appeared before me, the undersigned in and for the jurisdiction
aforesaid, the within named in the above and foregoing
instrument of writing, who acknowledged to me that he/she signed and delivered the above
foregoing instrument of writing on the day and in the year and for the purposes therein
mentioned.
GIVEN under my hand and official seal of office on this the day of
.
__________________________
NOTARY PUBLIC
My Commission Expires:
______________________
STATE OF MISSISSIPPI
COUNTY OF
PERSONALLY came and appeared before me, the undersigned in and for the jurisdiction
aforesaid, the within named in the above and foregoing
instrument of writing, who acknowledged to me that he/she signed and delivered the above
foregoing instrument of writing on the day and in the year and for the purposes therein
mentioned.
GIVEN under my hand and official seal of office on this the day of
20 .
__________________________
NOTARY PUBLIC
My Commission Expires:
_____________________
Page 6 of 7
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