Legal Special ROG Response

LEGAL SPECIAL ROG RESPONSE

Court:    Case Number:    Caption/Title:

Responding Party Name:    Requesting Party Name:

RECITALS

WHEREAS, on the Requesting Party served Special Interrogatories (the "Special Interrogatories") upon the Responding Party; and

WHEREAS, the Responding Party has conducted a reasonable and diligent inquiry and is furnishing responses and objections to the Special Interrogatories as set forth below; and

WHEREAS, these responses are provided without prejudice to any rights to supplement responses, to assert privileges, or to move for appropriate relief with the Court.

NOW THEREFORE, Responding Party states as follows:

1. DEFINITIONS

For purposes of these responses, the following definitions apply: "Document" means any writing, recording or photograph in the broadest sense; "You" or "Your" refers to the Responding Party identified above; "Communication" means any transmittal of information by any means. Terms not defined herein have the meanings commonly ascribed to them in federal and state practice.

2. GENERAL OBJECTIONS

Responding Party objects to the Special Interrogatories to the extent they seek information protected by the attorney-client privilege, the attorney work product doctrine, any applicable statutory privilege, or by protective order. Responding Party further objects to the Special Interrogatories to the extent they are vague, ambiguous, overbroad, unduly burdensome, compound, premature, or seek information not relevant to the subject matter of the action or proportional to the needs of the case. Subject to and without waiving these General Objections, Responding Party provides the following specific objections and responses.

3. SPECIFIC RESPONSES TO SPECIAL INTERROGATORIES

The numbered responses below correspond to the Special Interrogatories propounded. Each response is made subject to the General Objections stated above and any specific objection noted in the individual response.

4. PRIVILEGE LOG / WITHHELD MATERIALS

To the extent any documents or communications are withheld based on privilege or protection, Responding Party provides the following general description. A privilege log will be provided or supplemented as required by applicable rules and any court order.

5. SUPPLEMENTATION

Responding Party acknowledges a continuing duty to supplement or amend responses in good faith pursuant to applicable rules if additional information or documents are discovered.

6. VERIFICATION

I declare under penalty of perjury under the laws of the jurisdiction in which this declaration is executed that the foregoing responses are true and correct to the best of my knowledge, information, and belief after reasonable inquiry.

7. CERTIFICATION BY COUNSEL

The undersigned counsel certifies that a reasonable inquiry was made to ascertain the correctness and completeness of these responses, and that counsel has not intentionally submitted any statement known to be false.

8. PROOF OF SERVICE

The undersigned certifies that on the date set forth below service of these responses was made to the addresses of record by the method indicated.

9. MISCELLANEOUS PROVISIONS

Governing Law: This Response shall be governed by and construed in accordance with the laws of the state in which the district or superior court sits, without regard to conflict of law principles.

Entire Agreement: These responses constitute the entire written response of Responding Party to the Special Interrogatories and supersede any prior oral or written statements to the extent they relate to these responses.

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

Amendments and Waiver: No amendment, waiver, or modification of these responses will be effective unless in writing and signed by the party to be charged. Failure to assert a right or objection shall not constitute a waiver of such right or objection.

NOTICES

All notices or communications concerning these responses shall be in writing and delivered to counsel of record at the addresses provided above or as otherwise stated in the court record.

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