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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.


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12 Petitioner: _________________________ ) RESPONSES TO SPECIAL INTERROGATORIES
) SET ONE
13 and )
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14 Respondent:____________________________ )
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- 1 -
RESPONSES TO SPECIAL INTERROGATORIES
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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OF RECORD:

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NAME AND CAPACITY OF RESPONDING PARTY hereby responds and objects to the
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Special Interrogatories, Set One, as follows:
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13 General Statement

14 These responses are made solely for the purposes of this action. Each answer is subject to
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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
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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
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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 SPECIAL INTERROGATORIES
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
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discovery. The following responses are based upon information presently available to respondent and
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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.


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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 and every one of the responses set forth
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13 below.

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RESPONSES TO SPECIAL INTERROGATORIES