COURTS OF THE TRIAL DIVISION OF ANYTOWN, USA IDA IPAÑA : : Plaintiff, : : v. : : SHIGLEY'S SUPERMARKET, INC. : : Defendant. : Case No. 10-7575 PLAINTIFF'S ANSWERS TO DEFENDANT'S INTERROGATORIES 1(a) Ida Ipaña (b) Maiden name: Rockwell (c) DOB: 1/25/19XX (d) Anytown, USA (e) Married to Isaac Ipaña 2. Defendant's employees, including produce manager, Jessica Martin, and store manager, Alan Masters witnessed or have knowledge of the accident. Plaintiff is not in possession of the names or identities of other customers. 3. Unknown to plaintiff. 4. Defendant is referred to plaintiff's Civil Action Complaint. 5. This information is believed to be in the sole possession, custody and control of the defendant. 6. November 11, 20XX at approximately 9:45 a.m. 7. Cold and dry. 8. Boots with 2-inch heels.
9. Objection as the Interrogatory is vague and burdensome. 10. Objection as the Interrogatory is vague and burdensome. 11. To be supplied. 12. To be supplied. 13. To be supplied. 14. Publishers' Warehouse , 78356 Center Boulevard, Anytown, USA 11111. 15. Employed as telemarketer. 20% commission on all sales. Average weekly salary $400.00. 16. To be supplied. 17. To be supplied. ________________________________ MAXINE FONTANA, ESQUIRE MacDonald & Fontana One Hightower Place Suite 108 Anytown, USA 11111 Attorney ID # 090909 Attorneys for Plaintiff
VERIFICATION ____Ida Ipaña, Plaintiff_____ in the above-entitled action, having read the contents of the foregoing Answers to Defendant's Interrogatories verifies that its contents are true and correct to the best of her knowledge, information and belief. False statements made herein are subject to the penalties of the laws of Anytown, USA, relating to unsworn falsification to authorities. DATED: __December 1, 20XX __________ _____ Ida Ipaña __________
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