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by GH Carr · 1999 — Answers to Defendant State of Ohio's First Set of Interrogatories and First Request for Production of Documents to Plaintiff. George H. Carr.. A sample set of interrogatories is shown in Exhibit 10.12. c. Responses to interrogatories A party must usually answer interrogatories within 30 days of service of .... You are required to answer these. Interrogatories separately and fully in writing under oath and to serve a copy of your answers on the undersigned within 30 days .... Sep 12, 2011 — compel Sprint to answer Fourth Interrogatory Nos. ... Another instructive example comes from Semsroth, where this Court ruled that an.. ANSWER: REQUEST FOR PRODUCTION OF DOCUMENTS #1: Please attach a copy of each document set forth in Answer 14a. INTERROGATORY NO. 15: In .... Complainant, through her counsel, Snider and Fischer LLC, requests that the Agency respond to the following interrogatories. You are required to answer these .... Answer each Interrogatory. No question is to be left blank. If the answer to an. Interrogatory is “none” or “unknown”, that must be written as the answer.. Often, once you answer the questions, the other side will use the answers to gather more information. For example, you may state that you saw Dr. Jones. When .... Plaintiff [CLIENT'S NAME] hereby requests that Defendant [DEFENDANT'S. NAME] answer fully the following set of Special Interrogatories, in writing and under .... Jul 18, 2014 — answer nine interrogatories they have thus far refused to answer. ... The several examples that the judge then walked through demonstrate.. Pursuant to Rule 2-421, you are required to answer the following interrogatories within 30 days or within the time otherwise required by court order or by the .... You must indicate whether you are sending the answers to interrogatories for original and enforcement proceedings, Florida Family Law Rules of. Procedure Form .... by EL Miner · 1976 · Cited by 19 — party will be as truthful as possible in answering an interroga- tory. For example, since interrogatories may be directed to any party to a lawsuit," the defendant .... Jan 27, 2017 — The initial, written questions you answer are called interrogatories. ... Here are some sample interrogatories from Bucks County, Pennsylvania.. Pursuant to Tennessee Rule of Civil Procedure 26.05(2) these interrogatories are ... the extent possible with the reasons for not answering more fully to be set out ... For example, “a coin,” “a bottle of wine,” or “a shirt” would be an individual.. May 10, 2017 — Because you are swearing that your responses are true. For example, let's say you broke your leg in a motor vehicle collision and are asked to .... Provided [below] are sample Interrogatories which may assist you in discovering certain ... Court may not require an opposing party to answer some or all of your .... ANSWERS OF DEFENDANTS TO INTERROGATORIES ... pertaining to 7 forage samples for analysis, a copy of ... and water samples taken from Plaintiffs' fana.. Sep 25, 2020 — Forrest is an excellent example of how not to object to an interrogatory. The attorney in that case set out a boilerplate objection to a number of .... Apr 7, 2015 — For example: an employer, the telephone company, a landlord, ... the Information Subpoena must answer the questions served within 7 days.. Mar 26, 2008 — Your response of sworn written answers to Interrogatories or your response of ... For example, if you fail to identify a witness, in response to an .... serve a copy of such answers to such interrogatories and legible photocopies of all documents responsive ... e. the method used to obtain the blood sample; and.. Printing or in a sample responses to a pdf version of evidence during the marital interrogatories? Indiana law sample responses are there are important because .... specific examples of questions which the lawyer or his paralegal can use to draft the ... “contention” interrogatories, but recognize that you might not get answers .... What If I Object to Some of the Interrogatories? There are some circumstances where you don't have to answer an interrogatory question. For example, the .... Nov 3, 2020 — Answering Interrogatories Credit Card Debt One of the most ... Below are examples of how to answer interrogatories against junk debt buyers .... For example, Cook County Circuit Court Rule 2.1(d) provides that, for motions other than discovery motions, a responding party has 28 days to respond to a motion .... Use the printable template on CocoSign website to fill in a Answers To Interrogatories Sample 2010 Form simply. Read the rest of the tutorial to comprehend .... There are exceptions to waiver; for example, a delayed objection on the grounds of privacy. (Heda v. Superior. Court (1990) 225 Cal.App.3d 525, 530. [275 Cal.. Aug 20, 2019 — It's not required that a party amend interrogatory responses to reflect ... For example, the amended responses must comply with Cal Rules of Ct .... Nov 5, 2013 — A review of these Answers clearly reveals that this response is misleading as Judge. Watson chose to object to these Interrogatories and did not .... Further examples may be found in RCW 26.19.101(3) and RCW 26.19.101(4). ... If an interrogatory cannot be answered completely, answer as much as you can, .... to Plaintiff's First Request for Production and to provide better answers to Plaintiff's ... Defendant served answers to Plaintiff's Interrogatories on August 16, 2010. ... email to opposing_counsel@example.com Opposing Counsel, 123 Main Street .... Upon serving answers to Interrogatories to the respective ... telegrams, telexes, cables, telephone records, reports, tests, samples, studies, compilations of.. If the answer is “yes”, state: (a) date; (b) place; and (c) nature. Page 3. TO BE ANSWERED ONLY IN AUTOMOBILE ACCIDENT CASES. 25. State on what street, .... In law, interrogatories are a formal set of written questions propounded by one litigant and ... For an example of how interrogatories may be used, in a motor vehicle accident lawsuit an injured plaintiff ... usually, on a blank document with the questions on one side of the page and space for the answers on the other side.. Sample Interrogatories To Defendant Slip And Fall · Free Preview · Description · Related Forms · How to Guide .... Apr 14, 2021 — The answers to interrogatories may be used as evidence at trial or in a ... For example, a plaintiff may send interrogatories to the defendant, and .... Defendant(s) hereby make demand that the Plaintiff(s) answer the following Interrogatories pursuant to the Pennsylvania Rules of Civil Procedure 4001 et seq.. These include sample complaints, motions, answers, interrogatories and other similar pleadings and filings and can also include criminal court filings. The best .... 1 hour ago — WeidnerApartment HomesHorrorStory: Sample Interrogatories Interrogatories To Witness To Will - Fill Online ... Sample Responses to Form .... The party submitting the interrogatories may move for an order under Rule 37(a) with respect to any objection to or other failure to answer an interrogatory. If that .... DEFENDANT'S FIRST SET OF WRITTEN INTERROGATORIES, REQUESTS FOR ... Plaintiff is under a duty to supplement its responses in accordance with Rule .... 1. For each of your present employment, self-employment, business, commercial, or professional activities, answer the following divorce interrogatories sample: a.. What Should I Do After Serving Interrogatories? How to Make ... — Written answers from the employer and insurer can verify known facts, narrow the .... I certify under penalty of perjury under the laws of the State of. _ that the foregoing Answers/Responses to. Interrogatories are true and correct. Claimant's Name.. RESPONSES TO SPECIAL INTERROGATORIES ... 26 section 2030(£)(2) of the Code of Civil Procedure, plaintiffs will provide samples of advertisements.. The plaintiffs state that the answer to many of the defendants' interrogatories may, ... response to said claim for reimbursement, for example, denied or approved, .... If an interrogatory seeks information contained in a document, Plaintiff may attach a copy of the document in lieu of answering that interrogatory. If Plaintiff .... Sample Answers to Interrogatories - New York. Request for Interrogatories sample form. Plaintiff, Case No: v Defendant. Sample Interrogatory Answers in .... Nov 5, 2019 — Learn interrogatory basics, including a definition, tips on answering interrogatories, sample interrogatories and responses, and ways to craft .... Oct 10, 2020 — Moreover, responses to interrogatories must be signed under oath. ... Rather, a sample personal injury interrogatory about texting and driving is .... sample landlord tenant interrogatories Medical Malpractice Interrogatories To ... 1 Arizona Rules of Civil Procedure requests that the Defendant answer under .... The deponent, on deposition or on written interrogatory, shall ordinarily be required to answer all questions not subject to privilege or excused by the statute .... Plaintiff, by and through undersigned counsel and pursuant to Rule 33 & 33.1, Arizona Rules of Civil Procedure, requests that the Defendant answer, under oath .... interrogatories be spaced so as to permit the answering party to answer upon the interrogatory ... standard interrogatories include sample attestation clauses.. For example, most jurisdictions require the answers to be on the interrogatories form, or on a separate sheet which restates the question followed by the answer.. May 2, 2011 — The party answering the interrogatories shall restate each question, by photocopying it or otherwise, then insert the word "Answer" and .... They are best used to get answers to the following questions in your case: ... Here is a sample contention interrogatory in an employment discrimination case:.. by FW Joyner · 1962 · Cited by 1 — To what extent do answers to written interrogatories limit proof at trial? The question ... example, mistake, inadvertence, excusable neglect, or honest misunder-.. May 24, 2021 — In discovery, the parties (or their lawyers) are trying to get answers to questions about each ... Requests for Production – Like interrogatories, requests for production are made in ... A Real-World Example of Discovery Abuse.. right to modify these answers to Respondents' interrogatories upon the completion of discovery ... Hypothetically, for example, if the geographic market were.. Pursuant to court rules, Plaintiff submits these Answers to Interrogatories to Defendant. 1. Please state your full name, date of birth, any other names by which .... If your answer to interrogatory number 1 was yes, please set forth the nature of the ... §323.2 Sample: Motion for Order Permitting Discovery of Defendant's Profits .... Interrogatories and Requests for Production of Documents. Any other ... ANSWERS TO INTERROGATORIES. State the ... In responding to this Interrogatory,.. You may object to any request that asks you to answer two or more different questions in a single request. For example, “Please provide the names of all witnesses .... immediate or direct control must be consulted in responding to each interrogatory propounded herein. 2. If any of the following written interrogatories cannot be.. Jerry Greenberg and Idaz Greenberg hereby answer National Geographic Society'S ... Answer: The plaintiffs object to the interrogatory to the extent that some.. under a duty to answer all written discovery which is ... responding to discovery requests is that although ... example, in a child support case an interrogatory.. fully, under oath, and in accordance with Rule 33 of the Utah Rules of Civil Procedure, answer the interrogatories set forth herein within twenty eight (28) days .... ly burdensome interrogatories. Or the responding party might answer the interrogatories using the time period it believes is relevant. Example: Instructions.. Answer — Answer -If you got a summons and complaint from a creditor, you ... plaintiff must give you responses to the request for interrogatories .... In other words, a defendant is not required to answer any interrogatories ... of documents, for example, it will almost always be necessary to seek leave of the .... the specific request, or requests, to which the document is responsive. 6. To the extent that you believe any interrogatory is ambiguous, your answer should set .... Avvo, Massachusetts RMV Permit Test Cheat Sheet | 2020 Answers, How Many Interrogatories Must Be Answered? endobj This Standard Document contains .... Federal Rules of Civil Procedure 26 and 33, hereby submits the following objections and responses to the Interrogatories Directed to Plaintiff, Ashoor Rasho, by .... 4 hours ago — Answer to Civil Complaint Example Unique Best S Of Sample . ... florida michigan gauthier gary interrogatories answers notice attended .... You might be able to get $1,000 per lawsuit, plus actual damages, attorney's fees, and court costs. . Do your best to answer each question. . For example, a .... Copies of Pilot Travel's First Set of Interrogatories and plaintiffs' responses are attached to the Supporting ... For example, Interrogatories 4 and 5 ask whether.. A sample response to interrogatories that a party may use in civil litigation in ... preliminary statement, answers and objections, signature clause for answers, .... Examples of written interrogatories for a personal injury case include: ... Accordingly, when answering interrogatories a party would be wise to consult an .... Mar 6, 2005 — Sample Answers to Interrogatories. SDNY Pro Bono Panel Sample Forms/Documents. Attachment(s): PDF. Organization: U.S.D.C. Southern .... Fill sample answers to interrogatories: Try Risk Free. The PDFfiller rating at ... Form Popularity response to form interrogatories template. Form Popularity .... Oct 11, 2018 — OBJECTIONS AND RESPONSES TO INTERROGATORIES. Interrogatory No. 1. With regard to the document found in the Administrative .... example: INTERROGATORY NO. 6: Describe in complete detail the basis for the ... Complaint Counsel interposes this objection in its Answers to Interrogatory .... The party submitting the interrogatories may move for an order under Rule 37(a) with respect to any objection to or other failure to answer an interrogatory. Note:.. Mar 20, 2014 — RESPONSES TO FORM INTERROGATORIES ... were or might be insured in any manner (for example, primary, pro-rata, or excess liability .... May 24, 2021 — Answer. Tip: Check out the interrogatory sample and how to format a set of interrogatories in the Links & Files section below. Interrogatories.. It emphasizes the duty of the responding party to provide full answers to the extent not objectionable. If, for example, an interrogatory seeking information about .... (c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable .... (a) These Interrogatories are continuing in nature so as to require the filing of supplemental answers and responses without further request should additional .... Interrogatories to the plaintiff to be answered under oath not later than 60 days after the filing of ... exposure, please answer this Interrogatory with respect to the person involved in the primary ... samples of asbestos-containing materials;. (b).. Rules 16.2 and 33, additional interrogatories may be attached. Section 3. Instructions to the Answering Party. (a) An answer or other appropriate response must be .... For example, how many people suspended are African-American, how many Hispanic, how many are Caucasian, how many are Asian, etc. ANSWER: Defendant .... Answer: 2. State the names and addresses of all persons known to you or to your insurance company or attorney who witnessed any part of the incident, or have .... Aug 6, 2014 — This time, let's talk about lawyers obstructing discovery by responding to discovery interrogatories themselves, rather than by having their client .... At this juncture, the jury returns and the trial judge reviews the answers. If the answer to question I is "No," a verdict for the defendant is rendered. Part II. If the .... 9 hours ago — Posted July 11, 2021, 11:40 am to plaintiff example. plaintiff definition person ... answers interrogatories plaintiff defendant form fill defendants.. 6. The answers to these interrogatories shall be promptly supplemented and amended as required by Rule 26(e) of the Federal Rules of Civil Procedure. 7.. Jan 20, 2015 — It can be really daunting to receive a list of interrogatories to answer. Below is a list of sample replies that you can use as a baseline to answer .... its Answers and Objections to Plaintiffs' First Interrogatories. Republic reserves the right to amend or supplement these responses pursuant to the Federal Rules .... 2 hours ago — sample california motion compel special stipulation order eviction interrogatories requests stipulations documents responses further admission .... May 6, 2011 — Strategy is important, both in asking and answering Interrogatories. ... In these examples, you would not want to respond with your current .... Fill out, securely sign, print or email your Sample Answers to Interrogatories - Personal Injury Attorneys ... instantly with SignNow. The most secure digital .... Sample Electronic Data Interrogatory ... Plaintiff requests that Corporation answer the following special interrogatories separately and fully, in writing, and under .... Keep Your Answers Short and Simple ... Remember to keep your answers brief. One word answers are the best. Very rarely should an interrogatory answer be .... by KR Berman · 1993 · Cited by 1 — interrogatory answer is a speech or objection from the other side's lawyer. ... or that parrots back the question?for example, "the defen? dant manufactured a .... Free Consultation (800) 553-8082 Miller & Zois helps injured victims and their families in personal injury, medical malpractice and wrongful death cases.. Nov 15, 2008 — Unlike the previous procedure in the Supreme and District Courts, a party can no longer require another party to answer interrogatories by service .... by C HILL · 2015 — ANSWER TO INTERROGATORIES. Please identify ... For example, the Clerk has been forced to close the office from Noon to 1:00 pm each day .... Mar 29, 2019 — While courts typically require the party responding to interrogatories to retype ... The court may have sample interrogatories that include specific .... to either attach such as an exhibit to your answers to. 6 these interrogatories, or to ... samples of the decedent at any time? If your answer .is. 1! 16 !! in the.. Answers to Plaintiffs' Interrogatories. Swanson, Martin & Bell, Karen M. Zajicek, 2100 Manchester Road, C-1420, Wheaton, Illinois. 60187, (630) 653-2266, .... Jan 6, 2020 — Answers to Interrogatories must be signed under oath, so it is important that your ... Some examples might be attorney-client work-product or .... serve such answers on the United States within the time provided by Rule 33(b). In answering these Interrogatories, furnish all information available to you, .... Nov 5, 2018 — Defendant's refusal to answer interrogatories or to produce the requested. SICS documentation is without substantial justification, and plaintiffs .... Any party may serve upon any other party written interrogatories to be ... days after the service of the interrogatories, except that a defendant may serve answers .... Place a file-stamped copy of the Answers to Interrogatories in the file. Form 4-25 is a sample form used to answer interrogatories. Form 4-26 illustrates sample .... Interrogatories are a discovery device used by a party, usually a defendant, to enable the ... Sample interrogatories by a plaintiff, directed to a corporation .... Right here, we have countless book sample interrogatories answers to and collections to check out. We additionally come up with the money for variant types .... For example: INTERROGATORY NO. 3: Please describe your automobile. ANSWER NO. 3: I object that this interrogatory is vague. Without waiving this objection .... A party answering interrogatories must set out the interrogatory immediately preceding the answer thereto. Source: SDC 1939 & Supp 1960, § 36.0531; SD RCP, .... Defendant objects to this Interrogatory as overbroad, vague and ambiguous and to the extent that it requests information protected by the attorney-client privilege, .... Form 6.14 Answers to Interrogatories. UNITED ... FOR A SAMPLE DISTRICT ... by and through its attorneys, hereby answers the interrogatories submitted by .... If you ally infatuation such a referred sample interrogatories answers to book that will allow you worth, get the definitely best seller from us currently from several .... The defendant is requested to answer the following interrogatories under oath, and to attach to her answers copies of the documents designated below.. If there is no response to the Court Order requiring answers to the Interrogatories, then the judgment creditor must file a Motion to Incarcerate Judgment Debtor / .... Unless otherwise specified, further answers to interrogatories shall be served within ... The following examples illustrate what is permitted and what is forbidden:.. Below are sample answers to interrogatories in a product defect case against Walt Disney. Our client has a catastrophic brain injury. We make few objections to .... PLAINTIFF'S RESPONSES TO STYLE INTERROGATORIES PROPOUNDED TO ... was performed on decedent, were any specimens or tissue samples taken or.. Examples: "Exhibit 1 - Lease Agreement dated 12/31/05," or "Exhibit 2 - Bill of Sale dated. 1/1/06." Only answer one or more of the following questions if they are .... 7 hours ago — Sample California demurrer to answer Fillable Online GENERAL DENIAL ... supplemental interrogatories chap deputy counsel answer general.. responses and objections to the interrogatories sent to it by TransCanada Keystone Pipeline, LP. (“TransCanada”), dated December 18, 2014. Bold's answers .... The 3 Most Important Questions To Get Right When Answering Interrogatories in Your Personal Injury Case. Insurance defense lawyer asking interrogatory .... Jun 11, 2019 — While interrogatory responses can seem scripted and deposition ... For example, an RFA might ask whether the other side has any facts to .... If the answer to an interrogatory may be determined by examining, auditing, ... copy, test or sample the following items in the responding party's possession, .... ... also assists in preparing and answering interrogatories . There are resources available to assist in this process . For example , the state rules of civil procedure .... Connecticut Rules of Civil Procedure - Interrogatories Fairfield - Superior Court of Connecticut - Local and Federal Court Rules Made Easy.. 24. 25. 26. SAMPLE INTERROGATORIES - 4. (c) The date and place of the conviction and sentence imposed; and. (d) The court and case number. ANSWER:.. INTERROGATORIES TO PARTIES Rule Number Subset: .01... ... For example, a responding party may object to a Rule 33 interrogatory as overly broad on the .... Nov 15, 2020 — For example, the defendant in a personal injury lawsuit about a car ... If you still do not answer the interrogatories, the judge can assess a .... A response to a document request or interrogatory stating that objections and/or indicating that documents will be produced shall not be deemed or construed that .... You will likely be required to answer the questions and produce all the ... Arizona actually has a standard set of sample interrogatories that can be used in family .... [defendant][name of defendant]. Defendant. [action]Civil Action No. ______. INTERROGATORIES. The Plaintiff requests that the Defendant answer under oath, in .... For each person identified in your answer to the previous interrogatory, please state: (a). The person's relationship, if any, to the Defendant;. (b). The person's .... 301.0 Identity of Persons Answering These Interrogatories. 301.1 State the name, . DISC 1200 Civil Action Forms - Sample Request For Admissions Breach Of .... Feb 17, 2007 — Every lawyer knows that interrogatory answers are to be signed by the client, the party with substantive knowledge (Rule ... In Sample v. Miles .... Garnishee's Answers to Interrogatories for Earnings ... federal minimum hourly wage $7.25) times 30 times the number of weeks in this pay period For example:.. Read Online; Download | Printer-friendly; Download Sample Interrogatories and Requests for Production Form ... How do I use discovery answers at trial?. (b) The party upon whom the interrogatories have been served shall serve separate written answers or objections to each interrogatory within 30 days after service .... The Department objects to each Interrogatory and Request identified below insofar as it seeks production or disclosure of documents or information subject to .... Mar 26, 2018 — Plaintiff's response to Defendant's Interrogatory is made to the best of Plaintiff's ... responses may be substantially altered by further investigation, including further review of ... For example, to the extent the Interrogatory.. What is the name and address of the person answering these interrogatories, and, ... The above pleading is a sample of Alan Sackrin's 30-plus years of litigation .... Jul 5, 2004 — The defendant's motion asks the court to strike the paragraph contained at the end of each of the plaintiffs' answers to interrogatories.. Feb 1, 2015 — (a) In accordance with Rule 2-421(b), your response shall set forth the interrogatory, and its answer, and “shall answer each interrogatory .... Interrogatories may, without leave of court, be served upon the plaintiff after the ... The answers are to be signed by the person making them, and the objections .... Mar 29, 1974 — An interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or .... Defendants object to the Interrogatories and Requests for Production of Documents to the extent that they seek information protected by the attorney-client .... Typical civil interrogatories (case involved a boundary dispute) ANSWERS to ... the following sample interrogatories must be reduced to 25 interrogatories.. How to Answer Interrogatories — Formal or written questions that require an answer, by direction of the court. Origin. 1525-1535 Late Latin .... Responding to interrogatories properly is essential. Interrogatories can be used to help or hurt your case .... 4 hours ago — WeidnerApartment HomesHorrorStory: Sample Interrogatories Interrogatories To Witness To Will - Fill Online ... Sample Responses to Form .... The responding party must serve its answers and any objections within 30 days after ... An answer to an interrogatory may be used to the extent allowed by the ... If, for example, an interrogatory seeking information about numerous facilities or .... the answer to an interrogatory may be derived, or explained from business records of the party required to answer these Interrogatories or from an examination, .... PRC Sample Answer Sheet for Licensure Examination for Teachers, LET Exam ... 3. . appropriate uniform interrogatories within 60 days after service by that .... Case No. Defendant. ) ) INTERROGATORIES & REQUESTS. FOR PRODUCTION. I request that you: Answer the .... An interrogatory is not objectionable because an answer to it involves an opinion or ... Truck Accident – Company Sample interrogatories to defendant trucking .... If you do not answer an interrogatory question, and then the other side learns that ... Let's take the examples mentioned in What are interrogatories and how do .... How to Organize Your Responses to the Marital Interrogatories, Custody Interrogatories, or Parental Allocation Interrogatories. Below we explain the intial steps .... 9 hours ago — Posted July 11, 2021, 11:54 am to plaintiff example. plaintiff definition person ... answers interrogatories plaintiff defendant form fill defendants.. set forth in your answer to preceding subparagraph of this interrogatory. ... your answers to these interrogatories, providing the following information: a. the date .... Tierra further objects to the instructions and definitions accompanying Plaintiffs' interrogatories to the extent they are overly broad, not relevant, and not reasonably .... [DOWNLOAD] Sample Answers To Interrogatories Federal Court | new! Get sample interrogatories that show the best questions to ask depending upon the type .... using interrogatories for the responding party to provide responses. Cal. Code Civ. Proc. § 2030.040. See Cal. Code Civ. Proc. § 2030.050 for sample language .... Fill out the first page as shown in the sample. Put all your responses (answers) on the blank pages that are in this packet. Answer each interrogatory (question) .... P., Plaintiff hereby submits her answers to Defendant's. Uniform Interrogatories as follows: ANSWERS TO UNIFORM INTERROGATORIES. Interrogatory No.. A sample response to interrogatories for a party to use in New York civil ... and tips for drafting the caption, introduction, specific answers and objections, the .... The survey should take approximately 10 minutes and all responses are voluntary and will remain confidential. Thank you for your support Take survey».. In this article, we'll answer a few common questions related to interrogatories in ... In a case involving a slip and fall at a store, for example, your interrogatories .... When answer is made by a corporate Defendant, state the name, address and title of the person supplying the information and making the affidavit, together with .... In this example, the court found that the multi-part question counted as one interrogatory because all the ... Answers to interrogatories are provided under oath. 66cd677a50
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