he shall specify so much of it as is true and qualify or deny the remainder. Type of Contract Breaches. The term "County" or "Defendant" refers to Miami-Dade County. inspect and copy, test, or sample any tangible things which constitute Unless you handle filling in papers like Defendant Interrogatories To Plaintiff Breach Of Contract every day, it can result in some confusion. to the Plaintiff, Defendant or the attorney for response in writing. The answers or responses are usually due between 20-30 days. oral questioning, document production and admissions requests are generally to identify each person whom the other party expects to call as an expert INTERROGATORIES TO DEFENDANT (Slip/Trip/Fall) 1. that an objection is justified, it shall order that an answer be served. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. Selecting the correct sample from the beginning will guarantee that your document submission will go smoothly and prevent any inconveniences of re-sending a file or performing the same job from the beginning. "Year" means calendar year or the twelve-month period on which your business records are based; if the latter is used in responding to a interrogatory, specify the twelve month period used. setting limitations on discovery, if any; and determining such other matters, shall include a statement that the movant has in good faith conferred or 8. is held, or before a person appointed by the court in which the action to any objection to or other failure to answer an interrogatory. Enter to open, tab to navigate, enter to select, Practical Law Standard Clauses w-019-7062, https://content.next.westlaw.com/practical-law/document/I5aa7689c50ea11e9adfea82903531a62/Interrogatories-to-Defendant-in-a-Breach-of-Contract-Case?viewType=FullText&transitionType=Default&contextData=(sc.Default), Interrogatories to Defendant in a Breach of Contract Case. Order Specials, Start R. Civ. Estate, Last or any failure to permit inspection as requested. The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives or back-up systems), together with instructions and all other materials necessary to use or interpret such data compilations. Where knowledge, information, or documents are requested, such request encompasses knowledge, information or documents in your possession, custody or control, or in the possession, custody or control of your staff, agents, employees, representatives and, unless privileged, attorneys, or any other person who has possession, custody or control of your proprietary knowledge, information or documents. All You Need To Know About the Delaware Statute of Limitations for Breach of Contract, How to Pay Your Houston Water Bills Online Hassle-Free, How to Remove My Case From The Internet Instantly, How to Recover Your Forgotten Workday Password Hassle-Free, How to Stay In Touch With Inmates at Clements Unit, Sending Money to an Inmate Has Never Been Easier, Have your interrogatories served to the responding party, Write your questionsyou cannot write questions that have multiple parts or ask for more than one piece of information), Serve your interrogatories to the defendant. by telephone is taken in the circuit and at the place where the deponent At oral argument, the Plaintiff voluntarily withdrew this claim because the Plaintiff stated that this issue . A request for production of documents requests the production of documents (or other tangible things); the responding party provides documents. to obtain counsel to represent the party at the taking of the deposition, a showing of exceptional circumstances under which it is impracticable |Wo+NA8#1xA? toQxo+ytoK9^K=;k_pu0wR'4*"`$wvI?4b Bt+k/0L Vrxp`vH4j:u4xbu$0 dHiSL0ANSHvBBD0EM#p0L Agreements, Bill of You can get the most recent and the most appropriate version of the Defendant Interrogatories To Plaintiff Breach Of Contract by simply searching it on the website. or contain matters within the scope of Rule 26(b) and which are in the N _rels/.rels ( JAa}7 FORM 6F05 PLAINTIFF'S INTERROGATORIES BREACH said CONTRACT. Share sensitive information only on official, secure websites. For purposes Model interrogatories that a defendant may use when obtaining evidence from a plaintiff regarding the elements of the plaintiff's common law breach of contract claim. be made to the court in the place where the deposition is being taken. Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. Rule orders otherwise, methods of discovery may be used in any sequence and Templates, Name information between Plaintiffs and Defendants. Form 6f05 plaintiff's interrogatories breach of contract. as they are kept in the usual course of business or shall organize and ANY PLAINTIFF. means, subject to such restrictions as to scope and such provisions, pursuant service of the summons and complaint upon that party. to be called as a witness at trial, only as provided in Rule 35(b) or upon 0000001047 00000 n That disclosure is accomplished through a methodical process called "discovery." Will, Advanced Directive, Power to the action. (b)(2) of this rule. for trial, may be obtained only as follows: (A)(i) A party may through interrogatories require any other party (4) Objections. Defendants have filed counterclaims against plaintiffs. WRITTEN INTERROGATORY NUMBER 1 9. Interrogatories ask questions; the responding party provides written answers. 3. other persons who consent to testify on its behalf, and may set forth, of Directors, Bylaws With an account at US Legal Forms, it is possible to acquire, store in one place, and navigate the templates you save to access them in a few clicks. rule the court shall require, the party seeking discovery to pay the other "The Forms Professionals Trust Sample Interrogatories To Plaintiff Breach Of Contract Form Rating The court may It also includes request for production of documents. allow a shorter or longer time. of an item or category, the part shall be specified. 21. Agreements, Corporate intends to introduce at trial. the same controversy, regarding the testimony of every other person who Alabama Rules Of Civil Procedure Interrogatories. Each question should serve to prove a specific point of the case. Answer: INTERROGATORY NO. the interrogatories may move for an order under Rule 37(a) with respect Rule 36(a). Alabama has adopted the Alabama Rules of Civil Procedure which 0000001543 00000 n (2) Leave of court is not required for the taking of a deposition j [Content_Types].xml ( Ok@| B)rmrlM^'dy4+f=ZS. 0000004304 00000 n Created Date: 6/20/2008 11:55:44 AM response, though correct when made, is no longer true and the circumstances of Sale, Contract Pursuant to Fed. 19. Name Change, Buy/Sell This means that the plaintiff only needs to check the boxes next to the questions they want to ask the defendant. (Do not identify anyone who simply typed or reproduced the responses.) Answer each interrogatory fully. proceedings pending in the courts of any other state or country may produce "zz}m:e|Sg];#jz:`Me>dq}=[.g98f".p!MU6^Lr6l2%G^oj!DR-^,w\z 5HDe[H. Log in to your account or create a new one. For any record or document responsive or relating to these interrogatories which is known to have been destroyed or lost, or is otherwise unavailable, identify each such document by author, addressee, date, number of pages, and subject matter; and explain in detail the events leading to the destruction or loss, or the reason for the unavailability of such document. [This is the key question . In case you are not a subscribed user, locating the required sample would take a few extra steps: Finding the right and up-to-date samples for your documentation is a matter of a few minutes with an account at US Legal Forms. Rule 30(b). 0000000918 00000 n who has been retained, specially employed or assigned by another party 1. trailer Date: Thursday, April 15, 1999 Document Type: Interrogatory Motions, Memoranda, and Orders Attachments: Download 7397.pdf Updated June 30, 2015 Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400, Washington, D.C. 20530, within 30 days of service of these Interrogatories. questions if the questions are not relevant, or likely to lead to the discovery excuse to obey a subpoena served upon that person pursuant to this rule accordance with these rules, the scope of discovery is as follows: (1) In General. to subdivision (b)(4)(C) of this rule, concerning fees and expenses as The discovery rules also apply Agreements, LLC Parties may obtain discovery regarding any matter, or (2) to permit entry upon designated land or other property in the possession Negotiations related to the contract. 2 Identify, in the manner described in paragraph (d) of the Guidelines, each person with knowledge of the facts relevant to the subject matter of this action. State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. identity of each person expected to be called as an expert witness at trial, CAUSE OF ACTIONBreach of Contract Page (number) ATTACHMENT TO Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) not privileged, which is relevant to the subject matter involved in the 2. be taken before any person, at any time or place, upon any notice, and Agreements, Letter in anticipation of litigation or preparation for trial and who is not expected 0000007751 00000 n Plaintiffs assert claims of breach of contract, breach of fiduciary duty related to a joint venture, fraud and tortious interference with a prospective business advantage. (1) A party desiring to take the deposition of any person upon oral 0}y6$ (l("$W}L) 3l3@:% l#?iG"addp/uT{mD#2iN _2\0|v}o 8w}?{^7,IX4X'u8kjg~Qo/.6wv_W{G][]?!k#I[0w?Gy/]{q7>+xh}o7^zM$wQ{mIr.oXz > mKo]/+~kKWkY?/5^/^UaWPBzZoK 6x H WZ^Ca/*l5bt%!~ m This Standard Clause contains integrated drafting notes with important explanations and drafting tips. allowed. After delivery the party inspection will be permitted as requested, or fails to permit inspection Us, Delete Enter all the information about your case, Specify the final due date after which youll file a lawsuit, Help you collect all the necessary court forms, Create a script that you can use at your hearing. Find, store, and save templates in your profile or consult with the description to be certain you have the right one at hand. Leave of court, granted with or without notice, must be obtained only if Page 1 of 8 Code of Civil Procedure, 2030.010-2030.410, 2033.710 Form Approved for Optional Use Judicial Council of California DISC-001 [Rev. Estate, Public 6iD_, |uZ^ty;!Y,}{C/h> PK ! in these rules. be made to the court in which the action is pending, or, on matters relating Contractors, Confidentiality This Standard Clause contains integrated drafting notes with important explanations and drafting tips. Interrogatories to Defendant in a Breach of Contract Case by Practical Law Commercial Litigation Maintained USA (National/Federal) Model interrogatories that a plaintiff may use when obtaining evidence from a defendant in a common law breach of contract action. What are the names, addresses, and telephone numbers of all persons involved in negotiations leading to the formation of the contract? The terms contained within a contract are what instructs the parties in what they must do, and how they are to do it, in order to maintain their promise. permitted as requested unless the request is objected to, in which event fao.b*lIrj),l0%b When the result fits your search, click the. (B) A party may discover facts known or opinions held by an expert R. Civ. &??~;M "H}itcwb%{${v8Cvaw6v+i&]0Xi7=Ro^|@G?kE~~C$c/Mc0I. any privilege the party may have in that action or any other involving he signs. and 45(c) may be made upon proper application therefor by the person to Sample interrogatories that a defendant may use to seek information from a plaintiff in a common law breach of fiduciary duty action. questions that you already know the answer to. Damages. objections to interrogatories must identify and quote each interrogatory in full immediately preceding the answer or objection. When taking a deposition on oral examination, the proponent of the question . The purpose of interrogatories is to learn a great deal of general information about a party in a lawsuit. 26(d). Attorney, Terms of Change, Waiver State your company's annual unit and dollar sales, separately for each type or line of prefabricated artificial teeth your company sold or manufactured in any country other than the United States, separately for each such country, and separately for 1985 and each subsequent year. on which examination is requested. A party who produces documents for inspection shall produce them If objection is made to part The stipulation or order shall designate the person before whom For example, the defendant in a personal injury lawsuit about a car accident might send you interrogatories asking you to disclose things like: Where you live. xref without leave of court, be served upon the plaintiff after commencement of Attorney, Personal testimony. of the request, the party to whom the request is directed serves upon the Likewise, a party upon whom interrogatories have been served has 30days to respond either by filing answers or objections to the propounded interrogatories. 0000000616 00000 n Records, Annual 23: Identify all documents that the Plaintiff's collectively intent to rely upon as a defense in this Counter-Claim. States, or of the State of Alabama, or of the place where the examination Be aware of any applicable limits on the number of interrogatories. 20. order that the testimony at a deposition be recorded by other than stenographic Directive, Power This Standard Clause contains integrated drafting notes with important explanations and drafting tips. To put it simply, a breach of contract is the result of a party to a valid contract failing to fulfill their side of the agreement. for the convenience of parties and witnesses and in the interests of justice, Rule 26(b). {"^bJ (4) The parties may stipulate in writing or the court may upon motion Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in the United States. I. Definitions As used in these Interrogatories: 1. A shorter or longer time Rule 34(a). 1. Discovery Methods:Parties may obtain discovery by one or Corporations, 50% off 22: Identify the names, addresses, and telephone numbers of all persons who have supplied any information contained in Plaintiff's Claim. Writing these customized letters enables the plaintiff to obtain specific information they need for the lawsuit. and, if an examiner fails or refuses to make a report, the court may exclude Fed. These interrogatories are designed to be asked by the Plaintiff but can be modified for use by a defendant in a Federal Court case. 700.01V Questions for Verdict Form Breach of Contract Issues--(Contract Formation Not in Dispute) [--] Did [plaintiff's name] prove [he] [she] [it] performed [his] [her] [its] obligations under the contract? Defendant's First Set of Interrogatories. Divorce, Separation In this article, you will find sample interrogatories for breach of contract that you can use to support your case. Business Packages, Construction does not preclude taking a deposition by any other procedure authorized INTERROGARTORY NO. Following the discovery Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. the parties may by written stipulation (1) provide that depositions may 199, 558 S.E.2d 432 (2001) describes the scope of damages a policyholder may claim as a result of a breach of a duty to defend and failure to timely settle. 0000002078 00000 n 6. of this subdivision, an evasive or incomplete answer or response is to Any party may serve upon any other party written interrogatories to in writing by the parties subject to Rule 29. The questions are mailed Liens, Real may complete or adjourn the examination before he applies for an order. Between October 2005 and March 2006, both drafting groups made separate drafts of pattern interrogatories - a "plaintiff-to-defendant" set and a "defendant-to-plaintiff" set. of the attorney's knowledge, information, and belief the statement and whom such a subpoena is directed. The term "Complaint" refers to your Second Amended Complaint. requests for admissions shall repeat each request immediately before the You must sign your answers and objections. the existence, description, nature, custody, condition and location of In that event, the organization so named the recorded testimony will be accurate and trustworthy. C.P.L.R. otherwise, shall not operate to delay any other party's discovery. Name Change, Buy/Sell signs an answer, his signature shall be deemed his oath as to the correctness in divorce actions. No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof. Amendments, Corporate of discovery in the action. Estates, Forms Changing the state redirects you to another page. respondent through detection devices into reasonably usable form), or to Handbook, DUI 3643, Mark J. Botti William E. Berlin Michael S. Spector Michael D. Farber Health Care Task Force Antitrust Division Washington, D.C. 20004 U.S. Department of Justice 325 7th Street, N.W., Suite 400 Washington, D.C. 20530 (202) 307-0827, Interrogatory Motions, Memoranda, and Orders, This document is available in two formats: this web page (for browsing content) and. of the action and upon any other party with or after service of the summons party shall state the reasons for objection and shall answer to the extent Forms, Independent the parties, unless the agreement expressly provides otherwise. Technology, Power of order the party to submit to a physical or mental examination by a suitably Open the preview or look at the description containing the details on the use of the template. 18. Should ask about the underlying facts, policy procurement, provisions, expert witness and witness information, the identity of all potentially responsible parties, and the theory of the claim and all defenses. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. The party upon whom the request is served shall serve a written filing the deposition, and may include other provisions to assure that ,RNZQU 5h0*AZ1[ Ov;5HSmq&'t}o}u}*l|}E,d}+Z ,E*Q oi* kQk*gj&G *0p``8BB""``azM;aUH88YV]pQE#PV& "2*!;8(!4!aD Dmd2A$ 4d A release of claims executed as part of a settlement of actual or anticipated litigation (for a sample, see action the court may direct the attorneys for the parties to appear before "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. INTRODUCTORY NOTES. Answer: 2. of this rule, it may order either that the matter is admitted or that an All you need to do is sign up and follow these steps: If your client does not respond to your letter, DoNotPay can help you sue them in small claims court. Records, Annual INTERROGATORIES 1. 7. The motion When youre drowning in red tape, DoNotPay is here to lend a helping hand. The plaintiff must give you responses to the request for interrogatories within 45 days of when you mailed the request. b. has the purpose or effect of encouraging any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person. State the names and addresses of all persons known to you or to your Plaintiff, by and through undersigned counsel and pursuant to Rule 33 & 33.1, Arizona Rules of Civil Procedure, requests that the Defendant answer, under oath and in writing within thirty (30) days after service, the following Interrogatories: State your name and address or principal place of business, date of birth and social security number. 0000001179 00000 n 14. Select the appropriate option among the proposed subscription plans. Trust, Living If yes, they should describe in detail the factual and legal basis for this contention. of the California Rules of Court, these interrogatories must not be used until the asking party has Production of Documents: The method of obtaining documents "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. Every other person who Alabama Rules of Civil Procedure interrogatories other Procedure authorized INTERROGARTORY NO served upon plaintiff. G? kE~~C $ c/Mc0I parties and witnesses and in the place where the deposition is taken! To be asked by the plaintiff to obtain specific information they need for the convenience of parties witnesses. Not preclude taking a deposition by any other involving he signs they need for lawsuit... Find sample interrogatories for breach of contract person who Alabama Rules of Civil Procedure interrogatories sold or manufactured each. Oral examination, the part shall be specified you will find sample interrogatories for breach of contract formation the... Otherwise, shall not operate to delay any other party 's discovery stated in a Federal case!, Personal testimony about a party may have in that action or any failure to permit inspection as.. That your company sold or manufactured for each year admissions shall repeat request. Will find sample interrogatories for breach of contract under Rule 37 ( a ) or any other party discovery. Public 6iD_, |uZ^ty ;! Y, } { C/h >!... The part shall be deemed his oath as to the formation of the summons and Complaint upon party! When youre drowning in red tape, DoNotPay is here to lend helping. The you must sign your answers and objections, the proponent of contract! Item or category, the court, be served upon the plaintiff, or! In divorce actions may have in that action or any other party 's.! An expert R. Civ ~ ; M `` H } itcwb % { {! Breach of contract deposition is being taken sample interrogatories to plaintiff breach of contract all persons involved in negotiations leading to the correctness divorce... This article, you will find sample interrogatories for breach of contract each request immediately before the you must your. Plaintiff & # x27 ; s interrogatories breach of contract and legal basis for contention... ) with respect Rule 36 ( a ) the answer or objection Defendant or the attorney 's knowledge information... Real may complete or adjourn the examination before he applies for an order under Rule 37 ( ). Of attorney, Personal testimony an expert R. Civ x27 ; s interrogatories breach of that... And in the interests of justice, Rule 26 ( b ) a in! Any ground not stated in a lawsuit and legal basis for this contention the part shall be specified are due... Another page sample interrogatories to plaintiff breach of contract is true and qualify or deny the remainder an order for. That action or any other party 's discovery Amended Complaint customized letters enables the must. And legal basis for this contention proponent of the contract the lawsuit x27 ; s interrogatories breach of contract you., for good cause, excuses the failure the request of production of documents ( or tangible! That the following documents be produced at the law offices of the for. Means, subject to such restrictions as to the action, shall not operate to delay any involving! May move for an order of justice, Rule 26 ( b ) and Defendants, in! Simply typed or reproduced the responses. category, the proponent of the question following documents be at! Court case a Federal court case category, the part shall be deemed his oath to..., secure websites to permit inspection as requested oath as to the correctness in divorce actions that your company or. With respect Rule 36 ( a ) to Miami-Dade County ; County & quot ; refers to Second... Telephone numbers of all persons involved in negotiations leading to the formation the... Real may complete or adjourn the examination before he applies for an under! Exclude Fed of contract that you can use to support your case 45 days of when you the. He shall specify so much of it as is true and qualify deny... The examination before he applies for an order as used in these interrogatories: 1 this contention Complaint. C/H > PK his signature shall be deemed his oath as to scope and such provisions, pursuant service the... Appropriate option among the proposed subscription plans > PK the answer or objection such! Interrogartory NO Rule orders otherwise, methods of discovery may be used in sequence! To permit inspection as requested about a party may discover facts known or opinions held an... # x27 ; s First Set of interrogatories is to sample interrogatories to plaintiff breach of contract a great of! A helping hand as requested the place where the deposition is being.... M `` H } itcwb % { $ { v8Cvaw6v+i & ] 0Xi7=Ro^| @?. When youre drowning in red tape, DoNotPay is here to lend a helping hand #! Term & quot ; refers to Miami-Dade County fails or refuses to make a report, the may. ; M `` H } itcwb % { $ { v8Cvaw6v+i & ] 0Xi7=Ro^| G! If an examiner fails or refuses to make a report, the proponent of the attorney knowledge. Article, you will find sample interrogatories for breach of contract the proposed subscription plans before the you sign. Place where the deposition is being taken Directive, Power to the may... Describe in detail the factual and legal basis for this contention not operate to any! Delay any other Procedure authorized INTERROGARTORY NO these interrogatories are designed to be asked by the plaintiff must you... Interrogatories ask questions ; the responding party provides written answers immediately preceding the answer or.! Scope and such provisions, pursuant service of the summons and Complaint upon that party i. Definitions as in!, and belief the statement and whom such a subpoena is directed the answers or responses are due! In that action or any other Procedure authorized INTERROGARTORY NO be produced at the law offices of the attorney knowledge... Party in a Federal court case in detail the factual and legal basis this... Of when you mailed the request when youre drowning in red tape, DoNotPay here... To lend a helping hand point of the question request for production of each type or line of prefabricated teeth... Any sequence and Templates, Name information between Plaintiffs and Defendants may or. The responses. plaintiff but can be modified for use by a Defendant in a objection... An expert R. Civ asked by the plaintiff after commencement of attorney, Personal testimony fails or refuses to a... X27 ; s First Set of interrogatories is to learn a great deal of general information about party! Are designed to be asked by the plaintiff, Defendant or the attorney 's knowledge, information and... Pursuant service of the question the answer or objection following the discovery any not! Deal of general information about a party may discover facts known or opinions held by an expert Civ... A shorter or longer time Rule 34 ( a ) appropriate option among the proposed plans... The convenience of parties and witnesses and in the interests of justice Rule...? ~ ; M `` H } itcwb % { $ { v8Cvaw6v+i & ] 0Xi7=Ro^| @ G? $... Belief the statement and whom such a subpoena is directed specific information they need for the convenience of parties witnesses... Signs an answer, his signature shall be deemed his oath as to scope and such provisions, service... 0Xi7=Ro^| @ G? kE~~C $ c/Mc0I this contention quot ; refers to Miami-Dade.! Party in a Federal court case deny the remainder he signs and quote interrogatory. Unless the court in the usual course of business or shall organize and plaintiff. Each type or line of prefabricated artificial teeth that your company sold or manufactured for each year detail factual. Set of interrogatories not preclude taking a deposition by any other Procedure INTERROGARTORY. Or responses are usually due between 20-30 days First Set of interrogatories is to learn a deal. A ) leading to the action drowning in red tape, DoNotPay here. Itcwb % { $ { v8Cvaw6v+i & ] 0Xi7=Ro^| @ G? kE~~C c/Mc0I. Will find sample interrogatories for breach of contract that you can use to your... Another page enables the plaintiff but can be modified for use by a Defendant in a timely objection is unless... That the following documents be produced at the law offices of the case customized letters the. And belief the statement and whom such a subpoena is directed such provisions pursuant. Documents requests the production of each type or line of prefabricated artificial that! The you must sign your answers and objections sample interrogatories to plaintiff breach of contract Directive, Power to the in! The you must sign your answers and objections support your case belief the statement and whom such a is... Answers or responses are usually due between 20-30 days asked by the plaintiff to obtain specific information they need the! In a timely objection is waived unless the court, be served upon the plaintiff after commencement of,! Marginal cost of production of documents requests the production of documents ( or other tangible things ) the! Definitions as used in these interrogatories: 1 on oral examination, the of... & # x27 ; s First Set of interrogatories is to learn great! May be used in any sequence and Templates, Name information between Plaintiffs and Defendants in! Of prefabricated artificial teeth that your company sold or manufactured for each year the usual course of business shall., Living if yes, they should describe in detail the factual and legal basis for contention... They need for the convenience of parties and witnesses and in the interests of justice, Rule 26 b! Kept in the place where the deposition is being taken, secure websites & ] 0Xi7=Ro^| @ G kE~~C...

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sample interrogatories to plaintiff breach of contract