applicable, its officers, partners, employees, agents, representatives and attorneys. This
definition is not intended to impose a discovery obligation on any person who is not a
12. Person.
The term "person" is defined as any natural person or business, legal
or governmental entity or association.
13. Concerning.The term "concerning" means relating to, referring to, describing,
evidencing or constituting.
14. All/Each.The terms "all" and "each" shall be construed as all and each.
15. And/Or.The connectives "and" and "or" shall be construed either
disjunctively or conjunctively as necessary to bring within the scope of the discovery
request all responses that might otherwise be construed to be outside of its scope.
16. Singular/Plural and Past/Present Tense.Words in the singular include the
plural, and words in the plural include the singular. "Each" and "any" are both singular
and plural. Words in the past tense include the present, and words in the present tense
include the past. The word "including" should be construed without limitation.
17. Objections.If you deem any of the following interrogatories legally
objectionable, in whole or in part, you shall set forth all grounds for the objection in
sufficient detail to enable plaintiffs and the Court to determine the legal sufficiency of
such objection. If you object in part, you shall fully respond to such part or parts of the
interrogatory to which no objection is made.
18. Gender.Use of any terms denominating gender shall be construed to include
both the masculine and the feminine.
19. Claims of Privilege.If a claim of privilege is asserted concerning any
information sought or any document for which identification is requested, provide the
(a) Identify all communications by stating the participants in the
communication, the date of the communication, and the general subject
matter of the communication.
(b) Identify all documents by identifying the (i) type of document (letter,
memo, and so forth); (ii) general subject matter of the document; (iii)
date of the document; (iv) author(s), addressee(s), and recipient(s);
(c) State the nature of the privilege asserted; and
(d) State in detail the factual and legal basis for the claim of privilege.
INTERROGATORY NO. 1: Identify every person who has, or who you believe
may have, any knowledge or information relating to the matters alleged in the Plaintiff's
Complaint or in Defendants' Answer to said Complaint and state the knowledge or
information known or believed to be possessed by each such person.
INTERROGATORY NO. 2: Identify each person whom you may call as an
expert witness at the time of trial and, with respect to each such person, state the
(1) The subject matter upon which the person is expected to testify;
(2) The substance of the facts and opinions to which the person is
(3) The person's education and background identifying any and all articles,
books, other writings by this person; and
(4) A detailed and specific summary of the grounds for each opinion.
INTERROGATORY NO. 3: Identify each person who is a current voting
member of the organization and state the date upon which they became members of the
organization and the date they became voting members.
INTERROGATORY NO. 4: Identify each person with whom you have
communicated regarding the Plaintiff and/or his Complaint, identify each communication
and identify all documents referring, reflecting or relating to such communications. This
would include the dates and times of any public statement made to the organization
about the Plaintiff or that reflects upon Plaintiff, his character or his Complaint.
INTERROGATORY NO. 5: Describe in all possible detail all the facts and the
process involved, including who initiated all amendment documents, in obtaining the
board of trustees signatures on the amendments to the Articles of Incorporation and
whether it is the Defendants true understanding that all signatories to said documents
were then fully aware they were signing under oath with penalty of perjury, certifying
the filings as true and accurate, and whether all signatories then understood the contents
of the entire documents that they were signing and certifying.
INTERROGATORY NO. 6: Describe in all possible detail the extent of
audiotape or videotape records, listing the dates and times of such records.
