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Monica Graham
22365 Hayworth Court
Corona, CA 92883
951-316-3298
Monica_graham@rocketmail.com
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COUNTY OF RIVERSIDE
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Set no. 1
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Responding party:
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YOU ARE REQUIRED, pursuant to California Civil Code section 2031.010 et seq by and through
an authorized officer of your company, and that the response be signed by the person making them
and be served on Plaintiff, Monica Mitchell, within 30 days of service of these interrogatories at:
22365 Hayworth Court, Corona, California 92883.
Alleged Defendant requests full compliance with the provisions of the California Code of
Civil Procedure 2031.210 et seq, including the requirement that the Responding Party identify why
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certain documents are not being produced (i.e., documents have never existed, documents are lost,
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For purpose of responding to these requests, the term identify shall mean providing the full name,
aliases, title, work address and work telephone numbers, work email address of the person or entity.
Plaintiff means employee, agents, attorneys, investigators, etc. of Plaintiff in this action.
For purposes of responding to these requests, the term document shall mean all written or printed
matter of any kind, including originals, and all non-identical copies or otherwise, including, without
limitation, correspondence, e-mail, memoranda, notes, diaries, statistics, letters, telegraphs, minutes,
addenda, expense accounts, contracts, reports, studies, checks, statements, receipts, returns,
summaries, pamphlets, books, inter-office and intra-office communications, notations of any sort of
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teletypes, telefaxes, invoices, worksheets, any alterations, modifications, changes, and amendments
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all electronic, mechanical, or electric records or representation of any kind, including, but not limited
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For purposes of responding to these requests, the term Contract is the document that established a
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contract between Plaintiff and Alleged Defendant. Each of these requests is addressed to the personal
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and continuing knowledge of plaintiff and plaintiffs counsel. If plaintiff cannot respond to any
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request due to lack of information available to it, alleged defendant requests that the plaintiff respond
to those portions of the request it is able to answer and specifically state that portion of the request it
cannot answer due to lack of information, and provide a reason why it believes it lacks sufficient
information to respond. If any of these requests cannot now be answered because of lack of
information or documentation and such information or documentation subsequently comes to the
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supplemental documentation on alleged defendant within a reasonable time after such information or
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documentation is acquired.
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Interrogatory no. 1. Identify the person(s) who have answered these interrogatories.
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Interrogatory no. 2. Identify each and every person Plaintiff may call as a witness in this case, or
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other disposition of this matter, and provide a brief description of what you anticipate the witnesss
testimony to be.
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Interrogatory no. 3. Identify each and every document Plaintiff may introduce into evidence in this
case.
Interrogatory no. 4. Identify fully who the Lender is, as described in the Contract. If more than
one exists, state each.
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Interrogatory no. 5. State where in the Contract lender will change when the contract is sold.
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Interrogatory no. 6. Identify fully the individual who took the original Contract application.
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Interrogatory no. 7. Identify fully the person(s) who witnessed the Alleged Defendants signature
on the Contract.
Interrogatory no. 8. Identify fully the person(s) who have answered these questions.
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Interrogatory no. 9. State the date and amount(s) when the alleged amount in question was charged
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off.
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Alleged Defendant, Monica Graham, demands that the above-listed items be produced on or before
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Dated:______________________
By: ________________________________
Monica Graham
Alleged Defendant, Pro Per
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STATE OF CALIFORNIA
COUNTY OF Riverside
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ANN K. MERRILL
FULTON FRIEDMAN & GULLACE, LLP
2151 SALVIO STREET
SUITE W
CONCORD, CA 94520
I personally deposited with the U.S. Postal Service on that same day with
postage thereon fully prepaid at _Corona___________, California, in the ordinary
course of business. I am not a registered California process server.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on
3/14/2011
, at
Corona
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________________________________
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, California