Legal Interpellation Form

LEGAL INTERPELLATION FORM

This Legal Interpellation Form is served by Interpellant Name: of Address: to Interpellatee Name: of Address: for Matter/Cause Number: Date of Service:

RECITALS

WHEREAS, Interpellant is the party initiating the present inquiry and seeks documentary evidence, admissions and sworn responses from Interpellatee in connection with the Matter/Cause described above;

WHEREAS, Interpellant contends that specific facts and documents under the control or possession of Interpellatee are material and relevant to the claims and defenses in the Matter/Cause and that a written interpellation and request for production is necessary to clarify disputed matters;

WHEREAS, the parties intend that responses be made in good faith, verified under oath where indicated, and produced in a manner sufficient to permit meaningful inspection and use in litigation or settlement discussions;

NOW, THEREFORE, in consideration of the foregoing recitals and the mutual covenants contained herein, Interpellant hereby serves the following interpellation and requests that Interpellatee respond in accordance with the terms set forth below.

1. DEFINITIONS

For purposes of this Form, the following definitions apply: "Document" means all writings, drawings, graphs, charts, photographs, recordings, emails and electronic records, whether in paper or electronic form; "You" or "Interpellatee" refers to the named responding party and any agent, attorney or representative acting on its behalf; "Identify" with respect to a person means to state full name, last known business and residence address, and current or last known employer or affiliation.

2. INSTRUCTIONS TO RESPOND

Interpellatee shall answer each interrogatory separately and fully in writing under oath unless otherwise stated. If an interrogatory cannot be answered completely, answer to the extent possible and specify the reason for incomplete answer. All objections must be stated concisely and with specificity. The response must be signed by the person making it and by the attorney for Interpellatee if counsel represents Interpellatee.

3. FORMAT AND MANNER OF RESPONSE

Answers shall repeat the question or document request immediately preceding the answer. Unless otherwise agreed, provide one original signed verification and one electronic copy of responsive documents in PDF format on a read-only medium. Where documents are produced in native format, identify the producing file name and format. If privilege is asserted as to any document, provide a privilege log describing the document with sufficient detail to permit a determination of the claim.

4. VERIFICATION

Interpellatee must verify answers under penalty of perjury. Verification shall state: "I declare under penalty of perjury under the laws of the governing jurisdiction that the foregoing is true and correct." The verification must be dated, signed by the individual making the answers, and include the signer’s title and relationship to Interpellatee if the signer is not an individual.

5. DOCUMENT PRODUCTION

Produce all non-privileged documents responsive to a request in the manner specified above. For documents that are withheld in whole or in part under claim of privilege, supply a log itemizing the document number, date, author, recipient(s), subject matter and the specific privilege or protection asserted.

6. OBJECTIONS AND PRIVILEGE

An objection to an interrogatory or document request must state with particularity the grounds for objection. A general or boilerplate objection is insufficient. Where privilege is claimed, the responding party must, without disclosure of the privileged matter itself, provide sufficient information to permit a court to determine the applicability of the privilege.

7. DUTY TO SUPPLEMENT

If, after responding, Interpellatee learns that the response is incomplete or incorrect in any material respect, Interpellatee has a continuing obligation to promptly supplement or correct the response.

8. FAILURE TO RESPOND

Failure to serve timely and complete answers, or to produce responsive documents, may result in motions to compel, sanctions including costs and attorney fees, admission of facts, or other relief permitted by applicable rules and statute.

9. CONFIDENTIALITY AND PROTECTIVE ORDER

If Interpellatee designates produced material as confidential, Interpellant will treat such material as confidential subject to any protective order entered by the tribunal or agreed protective protocol. Designation does not eliminate the duty to produce a privilege log where applicable.

10. NOTICES

Notices and responses shall be deemed served when personally delivered, sent via overnight courier, or deposited in the United States mail, properly addressed and postage prepaid, or when transmitted by confirmed electronic mail to the addresses provided above.

11. GOVERNING LAW

This interpellation and any dispute arising out of or relating to the responses shall be governed by the substantive and procedural laws of the jurisdiction identified below. The parties submit to the exclusive jurisdiction of the courts of that jurisdiction for enforcement of any order or judgment.

12. ENTIRE AGREEMENT; SEVERABILITY; AMENDMENT

This Form constitutes the entire interpellation agreement between the parties with respect to the subject matter hereof. If any provision is held invalid or unenforceable, the remaining provisions shall continue in full force and effect. This Form may be amended only by a written instrument signed by both parties.

13. WAIVER; COUNTERPARTS

Waiver of any breach or provision of this Form shall not constitute a waiver of any other breach or provision. This Form may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one instrument.

14. INTERROGATORIES AND DOCUMENT REQUESTS

The following interrogatories and document requests are propounded to Interpellatee. Each interrogatory shall be answered separately and fully in writing under oath. Each document request requires production of responsive materials as described in Section 5.

Additional interrogatories or document requests attached to this form and signed by Interpellant are incorporated herein by reference.

15. CERTIFICATION OF SERVICE

I hereby certify that on I served the foregoing interpellation and any attachments to the parties at the addresses specified above by the following method(s):

Personal delivery U.S. Mail Overnight courier Email transmission

If served by email, indicate email address used for service:

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