Respondent Response to Interrogatories

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•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
•2345678910111213• 14151617181920212223242526• 2728iSPECIAL INTERROGATORY NO. 2:What date did you acquire an interest in Internet Megameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 2:I do not recall the exact date but I believe it was early in 2004. This informationshould be available from Internet Megameeting. The address is: 14900 Ventura Blvd.,#310, Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 3:What years did you get 1099 income during the period of 2006 -2008?RESPONSE TO SPECIAL INTERROGATORY NO. 3:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I received 1099 income the first half of 2006.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 4:What was the source of 1099 income in 2007?RESPONSE TO SPECIAL INTERROGATORY NO. 4:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence.SPECIAL INTERROGATORY NO. 5:What was source of 1099 income in 2006?RESPONSE TO SPECIAL INTERROGATORY NO. 5:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence.SPECIAL INTERROGATORY NO. 6:What was source of the brokerage income you cashed out in July 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 6:The funds cashed out in July 2009 came from investments I made with myRESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)3
Page 1: 1 CAROLE D. BALDWIN, CFLS, SBN 2133
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Page 9: 1234567VERIFICATIONI, MICHAEL CALDW

Respondent Response to Interrogatories

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