Respondent Response to Interrogatories

•12345678910111213141516171819202122232425such objections and grounds thereof are reserved and may be interposed at the time oftrial.The party on whose behalf the responses to special interrogatories are given hasnot yet completed investigation of the facts relating to this action, has not yet completeddiscovery in this action, and has not yet completed preparation for trial. Consequently,the following responses are given without prejudice to the answering party's right toproduce, at the time of trial, subsequently discovered material. Except for factsexplicitly admitted herein, no admission of any nature whatsoever is to be implied orinferred.The following interrogatory responses are given without prejudice toRespondent's right to produce evidence of any subsequently discovered fact or factswhich Respondent may later recall. Respondent accordingly reserves the right tochange any and all answers as additional facts are ascertained, analyses are made,research is completed, and contentions are made. The answers contained are made ina good faith effort to supply as much factual information and as much specification oflegal contentions as is presently known, but should in no way be to the prejudice ofRespondent in relation to further, discovery, research or analysis.All answers must be construed as given on the basis of present recollection.Any interrogatory deemed as continuing is objected to as oppressive, burdensome,improper, and not in compliance with California Code of Civil Procedure Sections 2016,2030 et seq., and will not be regarded as continuing in nature. Without waiving theforegoing, this responding party answers Petitioner's special interrogatories as follows:SPECIAL INTERROGATORY NO. 1:On January 1, 2008, what was your ownership of CSldentity?RESPONSE TO SPECIAL INTERROGATORY NO. 1:26Ido not know. Petitioner has submitted a subpoena to CSldentity, and the•2728information requested may be available through that subpoena. The address forCSldentity is: 7500 Rialto Blvd., #260, Austin Texas 78735.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 2