Responding party: __________ [Plaintiff or Defendant]
__________ [name]
Propounding Party: __________ [Plaintiff or Defendant]
__________ [name]
Interrogatory Set _____ [number of set]
Responding party, __________ [name], the __________
[plaintiff or defendant] in the above cause, makes the following
response to __________ [plaintiff's or defendant's] __________
[First or as the case may be] set of interrogatories, served on
__________ [responding party] on __________ [date]:
Response Number 1: __________ [If answering, set forth
complete and straightforward answer.]
Response Number 2: __________ [If electing option to
produce documents in lieu of answer, set forth the following:
Pursuant to section 2030(f)(2) of the Code of Civil Procedure,
__________ (plaintiff or defendant) elects to identify and
produce the following documents in lieu of answering this
interrogatory: __________ (list documents in enough detail to
permit propounding party to locate and identify documents from
which answer may be obtained, for instance: Reports of the
President's Committee of Tenure and Minority Faculty Recruitment
for the years 1980 through 1987). __________ (Plaintiff or
Defendant) may examine and copy the above documents at any time
after __________ (date), Monday through Friday, between the
hours of __________ (time) and __________ (time), at
__________(address), __________ (city), __________ County,
California.]
Response Number 3: __________ [If objecting to
interrogatory, clearly set forth specific ground for objection,
for instance: Objection. This interrogatory requests disclosure
of information protected by the work product rule, in that it
calls for disclosure of the contents of letters written by
defendant's attorney, __________ (name), to defendant in
preparation for litigation of this action.]
Verification
[Choose one of the following as appropriate:]
I, __________ [name], am __________ [plaintiff or
defendant] in the above cause of action. I have read the
__________ [number] Set of Interrogatories propounded to me by
__________ [plaintiff or defendant], __________ [name], and my
Response to those interrogatories. I am familiar with the
contents of both. Based on my knowledge, the responses to
__________ [plaintiff's or defendant's] interrogatories are
true.
I declare under penalty of perjury under the laws of the
State of California that the foregoing responses are true and
correct.
Dated __________.
____________________
[Signature]
Responding Party
[OR, if responding party lacks personal
knowledge of any matter in response]
I declare under penalty of perjury under the laws of the
State of California that the foregoing responses are true and
correct.
Dated __________.
____________________
[Signature]
__________ [capacity of signer]
[OR]
I, __________ [name], am authorized to verify this response
on behalf of __________ [organizational party], the __________
[plaintiff or defendant] in the above cause of action. I am
__________ [describe capacity of person verifying response, for
instance: President and Chief Executive Officer] of __________
[organizational party]. I have read the _____ [number] Set of
Interrogatories propounded to __________ [organizational party]
and the Response to Interrogatories. I am familiar with the
contents of both. I declare under penalty of perjury under the
laws of the State of California that the foregoing is true and
correct.
Dated __________.
____________________
[Signature]
Responding Party
__________ [If response contains any objections,
add the following: