1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of ________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) Special Interrogatories, Set One
)
13 vs. )
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14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )

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selling at a huge discount visit:
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SPECIAL INTERROGATORIES, SET ONE
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Be sure to remove these notices and all other notices before using
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6 this document.
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PROPOUNDING PARTY: ANY DEFENDANT
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RESPONDING PARTY: ANY PLAINTIFF
9

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SET NO.: ONE

11 TO: PLAINTIFF,_______________________, AND HIS ATTORNEYS OF RECORD:

12 Defendant, ____________________________________________ hereby request that

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Plaintiff,___________________________, answer the following special interrogatories,
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separately and fully in writing and under oath, pursuant to Code Of Civil Procedure 2030.010
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et. seq.
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17 INSTRUCTIONS TO THE ANSWERING PARTY

18 1. In Superior Court actions, an answer or other appropriate response must be given

19
to each interrogatory.
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2. As a general rule, within 30 days after you are served with these interrogatories,
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you must serve your responses on the asking party and serve copies of your responses on all other
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23 parties to the action who have appeared. See Code of Civil Procedure 2030.010 et. seq.

24 3. Each answer must be as complete and straightforward as the information

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reasonably available to you permits. If an interrogatory cannot be answered completely, answer
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it to the extent possible.
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4. If you do not have personal knowledge to fully answer an interrogatory, say so,
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SPECIAL INTERROGATORIES, SET ONE
 1 but make a reasonable and good faith effort to get the information by asking the other persons or
2 organizations, unless the information is equally available to the asking party.
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5. Whenever an interrogatory may be answered by referring to a document, the
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document may be attached as an exhibit to the response and referred to in the response. If the
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document has more than one page, refer to the page and section where the answer to the

7 interrogatory can be found.

8 6. Whenever and address and telephone number for the same person are requested in
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more than one interrogatory, you are required to furnish them in answering only the first
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interrogatory asking for that information.
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7. Your answers to these interrogatories must be verified, dated, and signed.
12

13 DEFINITIONS

14 1. "YOU" or "YOU OR ANYONE ACTING ON YOUR BEHALF" means you, the

15
Plaintiff,____________________. your agents, your employees, your insurance companies, their
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agents, their employees, your attorneys, your accountants, your investigators, and anyone else
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acting on your behalf.
18

19 2. "YOUR" or "YOURSELF" means ______________________, your agents, your

20 employees, your insurance companies, their agents, their employees, your attorneys, your
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accountants, your investigators, and anyone else acting on your behalf.
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3. "DOCUMENT" means a writing, as defined in Evidence Code 250, and includes the
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original or a copy of handwriting, type-writing, printing, photostating, photographing, and every
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25 other means of recording upon any tangible thing and form of communicating or representation,

26 including letters, words, pictures, sounds, or symbols, or combinations of them.

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4. "ADDRESS" means the street address, including, the city, state, and zip code.
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SPECIAL INTERROGATORIES, SET ONE
 1 5. "FULLY IDENTIFY" means in relation to persons to state the full name,
2 telephone number and last known address, including city, state and zip code; in relation to
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documents, "FULLY IDENTIFY" means to provide the name of the document, date of the
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document, and the type of document.
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6. "PERSON" includes a natural person, firm, association, organization, partnership,

7 business, trust, limited liability company, corporation, or public entity.

8 INSTRUCTIONS FOR THESE SPECIAL INTERROGATORIES

9
This set of special interrogatories has 56 interrogatories, you must
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11 modify and also add or subtract the following special interrogatories to

12

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fit the unique facts of your situation.
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Feel free to add your own special questions if you want. Just be
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16 sure that they are relevant to the case. Otherwise the other party will
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object to them.
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19 SPECIAL INTERROGATORIES

20 SPECIAL INTERROGATORY NO. 1:

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Do YOU contend that YOU STATE HERE THE SPECIFIC FACT THAT YOU WANT
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TO ASK THE RESPONDING PARTY IF THEY CONTEND SUCH AS PERFORMED ALL
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TERMS AND CONDITIONS OF THE CONTRACT ENTERED INTO BETWEEN YOU AND
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25 THE PROPOUNDING PARTY?

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SPECIAL INTERROGATORIES, SET ONE
 1 To purchase the entire 18 page document visit:
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SPECIAL INTERROGATORIES, SET ONE