Legal Interrogatory Response

LEGAL INTERROGATORY RESPONSE

Court:   Case No.:

Plaintiff:   Defendant:

Responding Party:   Date of Service of Interrogatories:

RECITALS

WHEREAS, on the date shown above the opposing party served written interrogatories pursuant to applicable rules of civil procedure; and

WHEREAS, Responding Party has reviewed the interrogatories, has made a reasonable inquiry, and furnishes the responses set forth in this document subject to the objections noted herein; and

WHEREAS, Responding Party reserves the right to supplement, amend, or correct these responses as additional information becomes known or available.

NOW, THEREFORE, in response to the interrogatories propounded by the opposing party, Responding Party states as follows.

1. DEFINITIONS

For the purposes of these responses, the following definitions apply: "Document" means any written, recorded or graphic material, including electronic files; "Interrogatories" means the specific numbered questions served on Responding Party; "Identify" applied to a person means to state the person's full name and last known address and, if a natural person, the present or last known employer.

2. GENERAL OBJECTIONS

Responding Party objects to each interrogatory to the extent it seeks information protected by the attorney-client privilege, the work product doctrine, or any other applicable privilege or protection. These objections are intended to be specific to each interrogatory and are not waived by the general statement of objections below. Responding Party further objects to any interrogatory to the extent it is vague, ambiguous, overly broad, unduly burdensome, or seeks information not reasonably calculated to lead to the discovery of admissible evidence.

Privilege claimed    Overbroad or unduly burdensome    Vague or ambiguous    Not relevant or not proportional

3. SPECIFIC RESPONSES TO INTERROGATORIES

Responding Party answers each numbered interrogatory as follows. Each response is subject to the General Objections and definitions set forth above.

4. PRIVILEGE AND PROTECTIVE CLAIMS

To the extent any documents, information, or communications responsive to an interrogatory are withheld based on privilege or protection, Responding Party asserts the privilege or protection and will, unless otherwise agreed or ordered, prepare and serve a privilege log identifying the document or information withheld, the basis for withholding, and sufficient detail to permit the opposing party and the court to assess the claim.

5. CONTINUING DUTY TO SUPPLEMENT

Responding Party acknowledges a duty to timely supplement or amend these responses if Responding Party obtains further information responsive to any interrogatory prior to trial. Any supplemental information will be provided in writing within a reasonable time after discovery of the additional information.

6. VERIFICATION

I declare under penalty of perjury under the laws applicable in this action that I have read the foregoing responses and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.

7. CERTIFICATE OF SERVICE

I certify that on , a true and correct copy of these responses was served on counsel for the opposing party by the following means:

NOTICES

MISCELLANEOUS PROVISIONS

Governing Law. This document and any dispute regarding its interpretation shall be governed by the substantive law of the jurisdiction in which the action is pending.

Entire Agreement. These responses, including the General Objections and any attachments specifically identified herein, constitute the complete written response of Responding Party to the interrogatories as of the date signed and supersede any prior oral or written statements on these topics.

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

Amendments; Waiver. These responses may be amended or supplemented in writing. No waiver of any provision or right shall be effective unless in writing and signed by the party against whom the waiver is asserted.

Counterparts. This document may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one instrument. Facsimile or electronic signatures shall be treated as originals for all purposes where permitted by law.

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