SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE-CENTRAL JUSTICE CENTER ) ) ) ) ) ) ) ) ) ) ) )

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1 Back to previous page: 0 ATTORNEY LAW OFFICES OF ATTORNEY Main St. Suite City, CA Telephone: ( - Facsimile: ( - attorney@law.com Attorney for Defendants, BILL H. AND LINDA B. NINA G., SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE-CENTRAL JUSTICE CENTER Plaintiff, v. BILL H., an individual; BOB H., an individual; LINDA B., an individual and DOES through, Defendants. PROPOUNDING PARTY: Defendant, LINDA B. RESPONDING PARTY: Plaintiff, NINA G. SET NUMBER: ONE Case No Case # Judge Franz E. Miller Dept. C- DEFENDANT LINDA B. S SPECIAL INTERROGATORIES, SET ONE PROPOUNDED TO PLAINTIFF Complaint Filed: /0/0 Defendant Linda B. requests that Plaintiff Nina G. answer the following special interrogatories under oath within thirty-five ( days from the date of service by mail, pursuant to California Code of Civil Procedure 00. et seq.

2 Back to previous page: 0 In answering these interrogatories, please furnish such information as is available to you, and not merely that which you know of your own personal knowledge. This means that you are to furnish information that is available to you or is within the knowledge of your attorneys, or their agents, employees, representatives, investigators or experts. (See CCP 00.0(cIf any of these Interrogatories cannot be answered in full, you are required to answer to the extent possible, specifying the reason for your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portion. (See CCP 00.0(a and (b DEFINITIONS Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: YOU and YOUR refers to Plaintiff Nina G. in the above-entitled action, and any third party, representative, or agent acting on her behalf and/or any third party upon whose behalf she is acting upon. COMPLAINT means the Plaintiff s Complaint filed on /0/0. DATE means to the day, month and year as can be verified or, if not verifiable, as near as can be recalled. DESCRIBE means to provide a comprehensive, complete, accurate, and detailed description, explanation, or listing of the matter inquired of. DOCUMENT means a writing, as defined in Evidence Code section 0, and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and form of communicating or representation, Case No

3 Back to previous page: 0 including letters, words, pictures, sounds, or symbols, or combinations of them. IDENTIFY with respect to a person means to provide the name, address (including city, state and zip code and telephone number. IDENTIFY with respect to a document means to state the nature of the document, its title, the date it bears and the location of the original and any copies thereof. PERSON includes a natural person, firm, association, organization, partnership, business, trust or corporation. SPECIAL INTERROGATORIES The COMPLAINT alleges in paragraph that Mr. [Jim] B. owned certain real property located on Lido Island and that his [Jim B.] Lido Island residence now belongs to the B. Estate, including Plaintiff. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : Explain what the phrase his [Jim B.] Lido Island residence now belongs to The B. Estate, including Plaintiff means. SPECIAL INTERROGATORY NO. : IDENTIFY all DOCUMENTS that show that the Lido Island residence belongs to YOU. SPECIAL INTERROGATORY NO. : Case No

4 Back to previous page: 0 Did YOU have title to, or legal ownership to, the Lido Island residence on the DATES that the acts alleged to have been committed by defendants in the COMPLAINT occurred? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number. DESCRIBE YOUR title or legal ownership to the property? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, on what DATE did YOU receive such title or legal ownership? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, by what means did YOU receive such title or legal ownership? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, what consideration was made for such title or legal ownership? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, IDENTIFY all DOCUMENTS that show you held legal title on the dates alleged. The COMPLAINT alleges in paragraph that the defendants trespassed upon the property and together they removed as much as they could carry out. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : Case No

5 Back to previous page: 0 State all facts upon which YOU rely to support this allegation. SPECIAL INTERROGATORY NO. : /// DESCRIBE the property. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants trespassed upon the property described in special interrogatory number. SPECIAL INTERROGATORY NO. : State the DATE or DATES these alleged acts of the defendants occurred. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who saw the defendants commit the act or acts alleged. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who can substantiate that the defendants committed the act or acts alleged. SPECIAL INTERROGATORY NO. : DESCRIBE what the defendants allegedly removed. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants committed the act or acts alleged. SPECIAL INTERROGATORY NO. : IDENTIFY the PERSON or PERSONS who held legal title the property described in special interrogatory number on the date or dates stated in special interrogatory number. Case No

6 Back to previous page: 0 SPECIAL INTERROGATORY NO. : IDENTIFY the DOCUMENT or DOCUMENTS that show legal title was held by the person or persons identified in special Interrogatory number. /// /// SPECIAL INTERROGATORY NO. : IDENTIFY the PERSON or PERSONS who had legal ownership of those items described in special interrogatory number. SPECIAL INTERROGATORY NO. 0: DESCRIBE by what right the person or persons identified in special Interrogatory number had legal ownership. SPECIAL INTERROGATORY NO. : State the value, showing the basis for the valuation, of those items described in special interrogatory number. The COMPLAINT alleges in paragraph that the personal items and property wrongfully converted by Defendants were items that Plaintiff legally owned and was legally entitled to possess. Special interrogatories numbers -0 refer to this allegation. SPECIAL INTERROGATORY NO. : DESCRIBE the personal items and property. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants converted the personal items and property. Case No

7 Back to previous page: 0 SPECIAL INTERROGATORY NO. : IDENTIFY all DOCUMENTS that show that the personal items and property described in special interrogatory number were legally owned by YOU. /// /// SPECIAL INTERROGATORY NO. : State the value, showing the basis for the valuation, of the personal items and property described in special interrogatory number. SPECIAL INTERROGATORY NO. : Did YOU have legal ownership to the personal items and property described in special interrogatory number on the date or dates the acts alleged occurred? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, DESCRIBE YOUR legal ownership to the personal items and property? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, on what DATE or DATES did YOU receive legal ownership? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, by what means did YOU receive legal ownership? SPECIAL INTERROGATORY NO. 0: If you answered yes to special interrogatory number, what consideration was made for legal ownership? Case No

8 Back to previous page: 0 The COMPLAINT alleges in paragraph that the defendants gained access to the property under false and misleading pretenses. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : State the DATE or DATES the acts alleged occurred. SPECIAL INTERROGATORY NO. : DESCRIBE the false and misleading pretenses. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants gained access. SPECIAL INTERROGATORY NO. : IDENTIFY any PERSON or PERSONS who can substantiate this allegation. SPECIAL INTERROGATORY NO. : DESCRIBE the the property. SPECIAL INTERROGATORY NO. : IDENTIFY the PERSON or PERSONS who held legal title the property described in special interrogatory number on the date or dates stated in special interrogatory number. SPECIAL INTERROGATORY NO. : IDENTIFY the DOCUMENT or DOCUMENTS that show legal title was held by the person or persons identified in special Interrogatory number. Case No

9 Back to previous page: 0 The COMPLAINT alleges in paragraph that the defendants caused the plaintiff damages in the form of monetary loss and heartache. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : State the monetary loss, showing how the amount of the loss is calculated. SPECIAL INTERROGATORY NO. : DESCRIBE what is meant by heartache and how the plaintiff was damaged by it. The COMPLAINT alleges in paragraph that Mr. H. knowingly and willfully enticed... B. to trespass upon the subject premises. Special interrogatories numbers 0- refer to this allegation. SPECIAL INTERROGATORY NO. 0: State all facts upon which YOU rely to support this allegation. SPECIAL INTERROGATORY NO. : Explain how Mr. H. enticed Ms. B.. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who saw the defendants trespass. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who can substantiate this allegation. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants trespassed. SPECIAL INTERROGATORY NO. : State the DATE or DATES that the alleged trespass occurred. Case No

10 Back to previous page: 0 The COMPLAINT alleges in paragraph, sub-section ( (and realleged in paragraph, sub-section ( that the defendants misled persons affiliated with the B. Estate (while still pending into believing that Plaintiff and Mr. B. were close friends with the defendants. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS to whom the defendants misrepresented themselves as alleged /// SPECIAL INTERROGATORY NO. : State the DATE or DATES the defendants misrepresented themselves to the persons identified in special interrogatory number. SPECIAL INTERROGATORY NO. : Explain what is meant by persons affiliated with the B. Estate. SPECIAL INTERROGATORY NO. : Explain how the defendants misrepresented themselves as alleged to the persons identified in special interrogatory number. The COMPLAINT alleges in paragraph, sub-section ( that the defendants intentionally removed Plaintiff s legally owned property from Plaintiff s home for financial gain. Special interrogatories numbers 0- refer to this allegation. SPECIAL INTERROGATORY NO. 0: Case No

11 Back to previous page: 0 State all facts upon which YOU rely to support this allegation. SPECIAL INTERROGATORY NO. : State the DATE or DATES the acts alleged occurred. SPECIAL INTERROGATORY NO. : DESCRIBE Plaintiff s home. SPECIAL INTERROGATORY NO. : DESCRIBE the property that was removed. SPECIAL INTERROGATORY NO. : Explain how the defendants removed the property. SPECIAL INTERROGATORY NO. : State the value, showing the basis for the valuation, of the property. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants financially gained from the removal of the property. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS that saw the defendants removing the property. SPECIAL INTERROGATORY NO. : Did YOU have legal ownership to the property on the date or dates identified in special interrogatory number? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, DESCRIBE YOUR legal ownership to the property? SPECIAL INTERROGATORY NO. 0: Case No

12 Back to previous page: 0 If you answered yes to special interrogatory number, IDENTIFY all DOCUMENTS that show the property was legally owned by YOU on the date or dates identified in special interrogatory number. SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, by what means did YOU receive legal ownership? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, what consideration was made for legal ownership? The COMPLAINT alleges in paragraph, sub-section ( that the defendants misled persons affiliated with the B. Estate into believing that the personal property and other items removed by the defendants was with a proper purpose. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who were misled by defendants as alleged. SPECIAL INTERROGATORY NO. : Explain how each of those persons identified in special interrogatory number 0 is affiliated with the B. Estate. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants misled the persons identified in special interrogatory number 0. SPECIAL INTERROGATORY NO. : Explain what proper purpose was. Case No

13 Back to previous page: 0 The COMPLAINT alleges in paragraph that the plaintiff was induced into allowing Defendants onto the subject property and that persons affiliated with the B. Estate were persuaded... regarding [Defendants] access to the personal property of Plaintiff. Special interrogatories numbers - refer to this allegation. SPECIAL INTERROGATORY NO. : State the DATE or DATES these alleged acts of the defendants occurred. SPECIAL INTERROGATORY NO. : DESCRIBE how the plaintiff was induced by the defendants. SPECIAL INTERROGATORY NO. : IDENTIFY all PERSONS who were persuaded by the defendants. SPECIAL INTERROGATORY NO. 0: DESCRIBE how each of those persons identified in special interrogatory number is affiliated with the B. Estate. SPECIAL INTERROGATORY NO. : DESCRIBE how the defendants persuaded the persons identified in special interrogatory number. SPECIAL INTERROGATORY NO. : DESCRIBE the personal property of Plaintiff. SPECIAL INTERROGATORY NO. : Case No

14 Back to previous page: Did YOU have legal ownership to the personal property described in special interrogatory number on the date or dates identified in special interrogatory number? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, DESCRIBE YOUR legal ownership to the personal property? SPECIAL INTERROGATORY NO. : If you answered yes to special interrogatory number, IDENTIFY all DOCUMENTS that show that the personal property was legally owned by YOU. Dated: ATTORNEY Attorney for Defendant Linda B. 0 DECLARATION FOR ADDITIONAL DISCOVERY TO DEFENDANT LINDA B. S SPECIAL G. v. H., et al. Case # I, ATTORNEY, declare: INTERROGATORIES, SET ONE PROPOUNDED TO PLAINTIFF. I am presently the attorney for Defendant Linda B., a party to this action.. I am propounding to Plaintiff Nina G.the attached set of Special Interrogatories, Set One. Case No

15 Back to previous page: 0. This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by Section of the Code of Civil Procedure.. I have not previously propounded interrogatories to this party.. This set of interrogatories contains a total of seventy-five ( specially prepared interrogatories.. I am familiar with the issues and the previous discovery conducted by all of the parties in the case.. I have personally examined each of the questions in this set of interrogatories.. This number of questions is warranted under Section of the Code of Civil Procedure because the complexity and quantity of existing and potential issues, the vagueness of the allegations in Plaintiffs Complaint against Defendant H. and the expedience of using this method of discovery to provide to the responding party the opportunity to conduct an inquiry, investigation, or search of files or records to supply the information sought all warrant a greater number of specially prepared interrogatories than the number permitted under section 00.00(a(.. None of the questions in this set of interrogatories is being propounded for any improper purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation. I declare under penalty of perjury under the laws of California that the foregoing is true and correct, and that this declaration was executed on 0. Case No

16 Back to previous page: ATTORNEY Attorney for Linda B. 0 Case No