1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

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Superior Court of the State of California
9 County of ___________

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11 In re the marriage of: ) Case No.

)
12 Petitioner: _________________________ ) RESPONSES TO FORM INTERROGATORIES-
) FAMILY LAW, SET ONE
13 and )
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14 Respondent:____________________________ )
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)
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RESPONSES TO FORM INTERROGATORIES-FAMILY LAW, SET ONE
 1 Be sure to remove these notices and all other notices before using
2

3
this document.
4 PROPOUNDING PARTY: NAME AND CAPACITY OF PROPOUNDING PARTY
5 RESPONDING PARTY: NAME AND CAPACITY OF RESPONDING PARTY
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SET NUMBER: ONE
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TO: NAME AND CAPACITY OF PROPOUNDING PARTY AND THEIR ATTORNEYS
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9
OF RECORD:

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NAME AND CAPACITY OF RESPONDING PARTY hereby responds and objects to the
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Form Interrogatories-Family Law, Set One, as follows:
12

13 General Statement

14 These responses are made solely for the purposes of this action. Each answer is subject to
15
all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all
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other objections and grounds which would require the exclusion of any statement herein if the
17
interrogatories were asked of, or any statements contained herein were made by, a witness
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19 present and testifying in court, all of which objections and grounds are reserved and may be

20 interposed at the time of trial.

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Except for explicit facts admitted herein, no answer or implied admissions are intended
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hereby. The fact that respondent answered any interrogatory shall not be taken as an admission
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that respondent accepts certain events or admits the existence of any fact set forth or assumed by such
24

25 interrogatory, or that such response constitutes admissible evidence. The fact that respondent

26 answered part or all of the interrogatories is not intended and shall not be construed to be a waiver of
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all or any part of any objection to any interrogatory made by respondent.
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RESPONSES TO FORM INTERROGATORIES-FAMILY LAW, SET ONE
 1 The factual background of this litigation is complex. Respondent will, during the course of
2 this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
3
discovery. The following responses are based upon information presently available to respondent and
4
are made without prejudice to respondents right to utilize subsequently discovered facts.
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To the extent that the interrogatories purport to require disclosure of confidential attorney-

7 client communications and/or protected work product, respondent objects. No waiver of privilege is

8 intended or should be implied from any of the responses to the interrogatories.

9
Discovery is continuing and the responding party reserves the right to amend these responses
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at a later date to incorporate later discovered facts and/or documents.
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This general statement is incorporated into each of the responses set forth below.
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form-interrogatories-for-divorce-in-california
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RESPONSES TO FORM INTERROGATORIES-FAMILY LAW, SET ONE