Respondent Response to Interrogatories

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12345678910111213• 14151617181920212223242526• 2728earnings from CSldentity.SPECIAL INTERROGATORY NO. 7:What dates did you do any type of work for Digital Infrastructure?RESPONSE TO SPECIAL INTERROGATORY NO. 7:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I do not recall the exact dates. I stopped performing any work for that companyin 2003. This information should be available from Digital Infrastructure located at14852 Ventura Blvd., #207, Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 8:How were you paid by Digital Infrastructure? Cash, Check, Other.RESPONSE TO SPECIAL INTERROGATORY NO. 8:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I was paid by check.SPECIAL INTERROGATORY NO. 9:How was income from Internet Megameeting reported on your taxes in 2008,and 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 9:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; vague and ambiguous as to the term "income." Without waiving statedobjections, I respond to this interrogatory as follows:I received K-1 income in 2008 and it was reported on my tax return on theSchedule E and 1040 forms. I did not receive K-1 income or any other type of incomefrom Internet Megameeting in 2009. It should be noted that the K-1s were for taxreporting purposes only. I never actually received money from Internet Megameeting.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)4
1•23456789101112130141516171819202122232425262728SPECIAL INTERROGATORY NO. 10:What date did you begin doing any work with Internet Megameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 10:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; assumes facts not in evidence; vague and ambiguous. Without waivingstated objections, I respond to this interrogatory as follows:I have never done any work with Internet Megameeting.SPECIAL INTERROGATORY NO. 11:What were the terms of you acquiring your partnership with InternetMegameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 11:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; assumes facts not in evidence. Without waiving stated objections, I respondto this interrogatory as follows:I am unable to answer this interrogatory. I do not have the documentation thatoutlines the terms of my partnership with Internet Megameeting. This informationshould be available from Internet Megameeting located at 14900 Ventura Blvd., #310,Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 12:Are you a trustee of any trust?RESPONSE TO SPECIAL INTERROGATORY NO. 12:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:No.SPECIAL INTERROGATORY NO. 13:What is the amount of rent you pay to your mother?RESPONSE TO SPECIAL INTERROGATORY NO. 13:I pay my mother $1,000 a month for rent.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)5
Page 1 and 2: 1 CAROLE D. BALDWIN, CFLS, SBN 2133
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Page 9: 1234567VERIFICATIONI, MICHAEL CALDW

Respondent Response to Interrogatories

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