Special Interrogatories
Michael Bruce, Esq. (SBN ABC5555)
14 12th Street, Suite 101
Seaside, California
555-555-6453
Attorney for Defendant Newsman
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SEASIDE
HART, ) Case Number 2004-14974-3
)
Plaintiff, ) SPECIAL
) INTERROGATORIES
v. )
)
NEWSMAN, et al., )
)
Defendant. )
______________________________)
PROPOUNDING PARTY: Defendant NEWSMAN
RESPONDING PARTIES: Plaintiff HART
SET NO.: ONE (1)
Pursuant to the Code of Civil Procedure §2030, defendant Newsman requests that plaintiff Hart serve verified answers to the following special interrogatories within 30 days after service hereof.
INTERROGATORIES
SPECIAL INTERROGATORY NO. 1:
STATE all facts supporting your allegations in paragraph 5 of your complaint which states that defendants trespassed on your property located at 961 Rincon Ave., in Seaside, Ca. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 2:
STATE all facts supporting your allegations in paragraph 5A of your complaint which states that defendants constructed a fence across your property located at 961 Rincon Ave., in Seaside, Ca. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 3:
STATE all facts supporting your allegations in paragraph 5B of your complaint which states that defendants modified landscaping on your property located at 961 Rincon Ave., in Seaside, Ca. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 4:
STATE all facts supporting your allegations in paragraph 5B of your complaint which states that defendants modified vegetation on your property located at 961 Rincon Ave., in Seaside, Ca. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 5:
STATE all facts supporting your allegations in paragraph 5C of your complaint which states that defendants entered your property located at 961 Rincon Ave., in Seaside, Ca, without permission. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 6:
STATE all facts supporting your allegations in paragraph 5D of your complaint which states that defendants attempted to exclude you from your property located at at 961 Rincon Ave., in Seaside, Ca. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
SPECIAL INTERROGATORY NO. 7:
STATE all facts supporting your allegations in paragraph 7 of your complaint which states defendant caused plaintiff to involuntarily vacate from plaintiff’s home. (AS SET FORTH IN THIS INTERROGATORY “STATE” MEANS TO SET FORTH A DESCRIPTION OF EACH FACT THAT REFERS OR RELATES TO YOUR ALLEGATION, THE DATE(S), LOCATION(S) OF EACH FACT, THE DATE, ADDRESSEE AND RECIPIENT OF EACH DOCUMENT REFERRING OR RELATING TO EACH FACT, AND THE NAMES, ADDRESSES AND TELEPHONE NUMBERS OF EACH PERSON HAVING KNOWLEDGE OF EACH FACT.)
July 15, 2004 __________________________________
Michael Bruce, Esq.
Attorney for Defendant Newsman
1
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Hart v. Newsman
Special Interrogatories to Plaintiff