Section 2544Knowledge or Reckless Disregard of Falsity
1.Do YOU contend that at the time that [here identify matter published or disclosed] YOU believed that such [statement, imputation, etc.] was true?
2.If your answer to interrogatory number 1 was yes, please set forth each fact that caused YOU to believe that such [statement, imputation, etc.] was true.
3.If your answer to interrogatory number 1 was yes, please IDENTIFY each PERSON who has knowledge of any fact that caused YOU to believe that such [statement, imputation, etc.] was true.
4.If your answer to interrogatory number 1 was yes, please IDENTIFY each WRITING relating to your belief that such [statement, imputation, etc.] was true.
5.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 4.
6.Do YOU contend that your belief that such [statement, imputation, etc.] was true was reasonable?
7.If your answer to interrogatory number 6 was yes, please set forth each fact that caused YOU to believe that such [statement, imputation, etc.] was true.
8.If your answer to interrogatory number 6 was yes, please IDENTIFY each PERSON who has knowledge of any fact that caused you to believe that such [statement, imputation, etc.] was true.
9.If your answer to interrogatory number 6 was yes, please IDENTIFY each WRITING relating to such contention.
10.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 9.
11.Do YOU contend that [here describe act of publication or disclosure] was not made with malice?
12.If your answer to interrogatory number 11 was yes, please set forth each fact upon which YOU base such contention.
13.If your answer to interrogatory number 11 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
14.If your answer to interrogatory number 11 was yes, please IDENTIFY each WRITING relating to such contention.
15.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 14.
16.Do you contend that prior to the time that YOU [here describe act of publication or disclosure], YOU conducted any factual investigation to determine whether such [publication or disclosure] was true.
17.If your answer to interrogatory number 16 was yes, please set forth the nature of the investigation undertaken by YOU.
18. If your answer to interrogatory number 16 was yes, please IDENTIFY each PERSON who participated in such investigation.
19.If your answer to interrogatory number 16 was yes, please set forth the date of such investigation.
20.If your answer to interrogatory number 16 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such investigation.
21.If your answer to interrogatory number 16 was yes, please IDENTIFY each WRITING relating to such investigation.
22.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 21.