Respondent Response to Interrogatories

12345678910111213• 14151617181920212223SPECIAL INTERROGATORY NO. 18:What items did you sell via paypal in 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 18:Objection: Not relevant to the proceedings before the court; overly-burdensome.Without waiving stated objections, I respond to this interrogatory as follows:I am unable to recall the exact nature of the items I sold on PayPal in 2009.Pursuant to C.C.P. section 2030.230, I refer Petitioner to the PayPal TransactionHistory provided in my response to her Request for Production and Inspection ofDocuments — Set Six.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 19:Who is owner of the plane in your airplane hangar?RESPONSE TO SPECIAL INTERROGATORY NO. 19:Objection: Not relevant to the proceedings before the court; not likely to lead toadmissible evidence. Without waiving stated objections, I respond to this interrogatoryas follows:Lea Caldwell is the owner of the incomplete airplane built from a kit stored in theairplane hangar.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 20:What is your ownership of CSIdentity?•2624252728RESPONSE TO SPECIAL INTERROGATORY NO. 20:Objection: assumes facts not in evidence. Without waiving stated objections, Irespond to this interrogatory as follows:I do not have sufficient information to be able to answer this interrogatory. Theinformation should be available from CSIdentity located at 7500 Rialto Blvd., #260,RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 7