Legal Responses to Ints

LEGAL RESPONSES TO INTS

This Legal Responses to Interrogatories is submitted in the action captioned Case Caption: , Case Number: , pending in Court: . Propounding Party: Responding Party: .

RECITALS

WHEREAS, Propounding Party served written interrogatories (hereinafter "Interrogatories") upon Responding Party in accordance with applicable rules of civil procedure on Date Served: ; and

WHEREAS, Responding Party is obligated to provide verified answers, objections, and any accompanying documents or privilege log responsive to said Interrogatories subject to the objections and limitations set forth below; and

WHEREAS, the parties wish to set forth the Responses and Objections in a written form to reduce dispute and establish the record.

NOW THEREFORE

Responding Party, by and through the undersigned, hereby furnishes the following Responses and Objections to the Interrogatories propounded by Propounding Party. The responses set forth are made subject to the General Objections and specific provisions contained in this instrument.

1. DEFINITIONS

For purposes of these Responses, the following definitions apply:

(a) "Document" or "Documents" means writings, drawings, graphs, charts, recordings, electronic files, photographs, communications, and other tangible things within the meaning of the applicable rules of civil procedure.

(b) "Identify" when used with reference to a natural person means to state the person's full name, present or last known business affiliation, and last known business address. When used with reference to a document, it means to state type, date, author and recipient, and current location.

2. GENERAL OBJECTIONS

Responding Party incorporates the Definitions above as if fully set forth herein and states the following General Objections which apply to all Responses and are not waived by providing any specific Response:

2.1 Responding Party objects to each Interrogatory to the extent it seeks information protected by the attorney-client privilege, the attorney work-product doctrine, common-interest or joint-defense privileges, or any other applicable privilege, and will provide a privilege log identifying privileged materials asserted, subject to protective order. To assert privilege, describe basis:

2.2 Responding Party objects to each Interrogatory to the extent it is overly broad, unduly burdensome, vague, ambiguous, compound, or not reasonably calculated to lead to the discovery of admissible evidence. Such objections are made without waiving the right to seek a protective order or to provide responses limited in scope.

2.3 Responding Party objects to any Interrogatory to the extent it seeks information not within Responding Party's possession, custody, or control. To the extent responsive information is located with third parties, Responding Party will identify the holder when known.

3. SPECIFIC RESPONSES TO INTERROGATORIES

The following are Responding Party's numbered responses. Each response is made subject to the General Objections above.

Interrogatory No. 1: State your full name, address, date of birth, and present employment.

Interrogatory No. 2: Describe in detail all facts upon which you base your allegations or defenses in this action.

Interrogatory No. 3: Identify each document or tangible thing that you contend supports your position and state where each document is located and the custodian.

Interrogatory No. 4: If you contend any fact concerning damages, list each damage component and the method of calculation.

4. PRIVILEGE LOG (IF APPLICABLE)

To the extent any document responsive to the Interrogatories is withheld on a claim of privilege or other protection, Responding Party will provide a privilege log containing, at minimum, the following information for each withheld document:

5. CONTINUING DUTY

Responding Party states that these Responses are given based upon present knowledge, information, and belief, and Responding Party will supplement or amend these Responses pursuant to the requirements of the applicable rules of civil procedure upon discovery of additional information or documents.

6. VERIFICATION

I, the undersigned, declare under penalty of perjury under the laws of the state specified in the Governing Law clause below that I am authorized to make these Responses on behalf of Responding Party, that I have read the foregoing Responses and that the information contained therein is true and correct to the best of my knowledge, information, and belief.

Printed Name of Verifying Person: Title/Capacity:

7. NOTICES

8. GOVERNING LAW; MISCELLANEOUS

Governing Law: These Responses shall be governed by and construed in accordance with the laws of the State of without regard to conflict-of-law principles.

Entire Agreement: These Responses, including the General Objections and any incorporated privilege log, constitute the entire statement of Responding Party with respect to the interrogatories served and supersede any prior oral or written statements on the same subject.

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

Amendments and Waiver: No amendment, modification, or waiver of any provision contained in these Responses shall be effective unless in writing and signed by the party sought to be bound. The failure to enforce any provision shall not constitute a waiver of the right to enforce that provision later.

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