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 County of ___________

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11 In re the marriage of: ) Case No.

)
12 Petitioner: _________________________ ) RESPONSES TO SPECIAL INTERROGATORIES
) SET ONE
13 and )
)
14 Respondent:____________________________ )
)
)
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)
)
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)
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RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
 1 http://legaldocspro.net/california-discovery-litigation-document-
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6 this document.
7 PROPOUNDING PARTY: NAME AND CAPACITY OF PROPOUNDING PARTY
8
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

12 OF RECORD:

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NAME AND CAPACITY OF RESPONDING PARTY hereby responds and objects to the
14

15 Special Interrogatories, Set One, as follows:

16 General Statement
17
These responses are made solely for the purposes of this action. Each answer is subject to
18
all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all
19
other objections and grounds which would require the exclusion of any statement herein if the
20

21 interrogatories were asked of, or any statements contained herein were made by, a witness

22 present and testifying in court, all of which objections and grounds are reserved and may be
23
interposed at the time of trial.
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Except for explicit facts admitted herein, no answer or implied admissions are intended
25
hereby. The fact that respondent answered any interrogatory shall not be taken as an admission
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27 that respondent accepts certain events or admits the existence of any fact set forth or assumed by such

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

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RESPONSES TO SPECIAL INTERROGATORIES, SET ONE
 1 answered part or all of the interrogatories is not intended and shall not be construed to be a waiver of
2 all or any part of any objection to any interrogatory made by respondent.
3
The factual background of this litigation is complex. Respondent will, during the course of
4
this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
5

6
discovery. The following responses are based upon information presently available to respondent and

7 are made without prejudice to respondents right to utilize subsequently discovered facts.

8 To the extent that the interrogatories purport to require disclosure of confidential attorney-
9
client communications and/or protected work product, respondent objects. No waiver of privilege is
10
intended or should be implied from any of the responses to the interrogatories.
11
Discovery is continuing and the responding party reserves the right to amend these responses
12

13 at a later date to incorporate later discovered facts and/or documents.

14 This general statement is incorporated into each and every one of the responses set forth
15
below.
16

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RESPONSES TO SPECIAL INTERROGATORIES, SET ONE