Section 2537Matter Disclosed as “Private Fact”
1.Do YOU contend that [here identify fact revealed] was not publicly known before prior to [here set forth act resulting in disclosure of private fact]?
2.If your answer to interrogatory number 1 was yes, please state each fact upon which YOU base such contention.
3.If your answer to interrogatory number 1 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
4.If your answer to interrogatory number 1 was yes, please IDENTIFY each WRITING relating to such contention.
5.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 4.
6.Do YOU contend that [here identify fact revealed] was the not the subject of any prior public disclosure?
7.If your answer to interrogatory number 6 was yes, please state each fact upon which YOU base such contention.
8.If your answer to interrogatory number 6 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
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 identify fact revealed] was not known by any person other than plaintiff before [here set forth act resulting in disclosure of private fact]?
12.If your answer to interrogatory number 11 was yes, please state 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.