Legal Interrogatories Responses

LEGAL INTERROGATORIES RESPONSES

Court:   Case No.:

Plaintiff:   Defendant:

RECITALS

WHEREAS, on , Interrogatories and Requests for Production were served upon Responding Party by Plaintiff/Propounding Party; and

WHEREAS, Responding Party has reviewed the Interrogatories and hereby provides the following objections and responses, subject to the General Objections set forth below and the reservation of rights to supplement or amend these responses as additional information becomes available.

NOW, THEREFORE, Responding Party submits these Responses to Interrogatories as follows.

1. DEFINITIONS

For purposes of these Responses, the following definitions apply: "Document" means all writings or recordings as broadly defined by the applicable rules of civil procedure; "You" or "Responding Party" means including its agents and attorneys; "Identify" with respect to a natural person means to state full name, present or last known address and telephone number, and the person's relationship to the matter.

2. GENERAL OBJECTIONS

Responding Party objects to each Interrogatory to the extent it seeks discovery that is not relevant to any party's claim or defense, is overbroad, unduly burdensome, vague, ambiguous, or inconsistent with the rules of civil procedure. These objections are asserted without waiver of Responding Party's right to contest the propriety of any particular objection or to move for a protective order. Responding Party also objects to any Interrogatory to the extent it calls for information protected by the attorney-client privilege, the attorney work-product doctrine, or any other applicable privilege or protection. Where privilege is asserted, documents and communications withheld are identified on a privilege log which will be produced if required by the Court.

3. RESPONSES TO INTERROGATORIES

The numbered Responses below correspond to the numbered Interrogatories propounded. Each Response is made based on information presently known or reasonably available to Responding Party after reasonable inquiry. Responding Party reserves the right to supplement these Responses.

Interrogatory No. 1:

Objection asserted?   If objecting, state grounds:

Interrogatory No. 2:

Objection asserted?   If objecting, state grounds:

Interrogatory No. 3:

Objection asserted?   If objecting, state grounds:

Interrogatory No. 4:

Objection asserted?   If objecting, state grounds:

Interrogatory No. 5:

Objection asserted?   If objecting, state grounds:

4. SUPPLEMENTATION

These Responses are made subject to Responding Party's continuing duty to supplement or amend pursuant to the applicable rules of civil procedure. Responding Party will provide supplemental responses promptly upon discovery of additional responsive information.

5. PRIVILEGE, WORK PRODUCT, AND DOCUMENT WITHHOLDING

Responding Party objects to any request to the extent it seeks production of privileged communications or materials prepared in anticipation of litigation. Privileged or protected materials have been or will be withheld, and a privilege log describing the withheld materials will be provided where required. Privilege asserted:   Work product asserted:

6. REQUESTS FOR ADMISSIONS AND DOCUMENTS INCORPORATED

To the extent any Interrogatory incorporates by reference any Request for Admission or Request for Production, Responding Party's answers herein are provided subject to the same objections and reservations stated in response to those requests.

7. NOTICE AND SERVICE

8. VERIFICATION

I, , declare under penalty of perjury under the laws of the State of that I have read the foregoing Responses to Interrogatories and that the answers contained herein are true and correct to the best of my knowledge, information, and belief formed after reasonable inquiry.

9. MISCELLANEOUS PROVISIONS

Governing Law: This Verification and these Responses shall be governed by and construed in accordance with the substantive laws of the State of , without regard to conflicts of law principles.

Entire Agreement: These Responses constitute the complete and final responses of Responding Party to the Interrogatories identified herein and supersede any prior oral or written responses concerning the same subject matter.

Severability: If any provision of these Responses is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

Amendments: These Responses may be amended or supplemented upon discovery of additional information, subject to the applicable rules of civil procedure.

Counterparts: This Verification and Responses may be executed in counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument.

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