DEFENDANTS’ FIRST SET OF INTERROGATORIES

YOUR NAME

Street Address

City, State Zip

Phone Number (with area code)

Fax Number (If applicable)

Email Address (If applicable)

Plaintiff In Pro Per

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF VENTURA
JESSE RIOS, JHONATHAN RIO, and ROSALVA VILLALVAZO,

                   Plaintiffs,

     Vs.
OSCAR VASQUEZ, individually & dba EXPERTS OF REAL ESTATE & CAL REAL ESTATE EXPERTS, and

Does 1 through 25, inclusive 

                  Defendant(s)

 Case No.: 56-2020-00546134-CU-BC-VTA

 

 

FIRST SET OF INTERROGATORIES

 

TO PLAINTIFFS JESSE RIOS, JHONATHAN RIO AND ROSALVA VILLALVAZO AND THEIR ATTORNEY(S) OF RECORD:

Defendants hereby request that Plaintiffs answer this first set of interrogatories separately and fully in writing and under oath pursuant to CA Civ Pro Code § 20130.010 (2019). 

 

DEFENDANT’S FIRST SET OF INTERROGATORIES TO THE PLAINTIFF 

Pursuant to CA Civ Pro Code § 2030.010 (2019) et seq., the Defendants requests that the Plaintiffs answer the following Interrogatories within thirty (30) days as required by law. 

In answering the attached interrogatories, furnish all information that is available to you, including all non-privileged information in the possession of your attorney(s), and any other persons employed by you or on your behalf and not merely such information known to you as a matter of personal knowledge.  Any reference made to “you” includes every person in connection with you as Responding Party, including all agents, employees, and other persons acting on your behalf.   

  If you cannot answer the following interrogatories in full, after exercising due diligence to secure information to do so, so state, and fully answer each interrogatory. Specify why you were unable to answer the remainder of any interrogatory.  Finally, state whatever information or knowledge you have concerning the unanswered portions of any interrogatory.   

  If an interrogatory does not specifically request a fact and such fact(s) is necessary to make the answer to the interrogatory comprehensive, complete, or not misleading, you shall include such facts as part of your answer.  The interrogatory shall be deemed specifically to request such fact(s). 

In each instance where Responding Party claims insufficient knowledge or information as a ground for not providing information or for providing only a portion of the information requested, a description must be provided of the efforts made to locate the information necessary for the answer. 

 

  1. DEFINITIONS 
  2. “DESCRIBE” and “SPECIFY” and “EXPLAIN” and/or “STATE” shall mean to set forth fully and unambiguously, using technical terms or words of art necessary, each and every fact and event relevant to the answer called for in the interrogatory, and if which the Plaintiffs or agents, representatives, attorneys, and all other persons acting for, or on behalf of, the Responding Party has knowledge. 
  3. “IDENTIFY” when referring to an individual, means to state: His/her full name; his/her present address if known or last known address if present address is unknown; and, his/her home and business telephone number. 
  4. “IDENTIFY” when referring to a document means to state: The type of document (e.g. letter, record, journal, memorandum), the date, title and identifying number of the document, if any, the general subject matter of the document, and the present location of the document. 
  5. The term “DOCUMENT” or “DOCUMENTS” shall mean to refer to all writings, and shall specifically include, but is not limited to, the original and all copies of any written material, including agreements, contracts, communications, correspondence, memos, telegrams, facsimiles, memorandum, notebooks, and summaries or records of telephone conversations, personal conversations and interviews. 
  6. “PERSONS” and/or “INDIVIDUAL” shall mean any individual, partnership, firm, corporation, trust, association, commission, board, proprietorship, authority, governmental agency or entities, and also where relevant, individuals representing such “PERSON” or “INDIVIDUAL.” 
  7. The term “YOU” and “YOUR” shall either mean JESSE RIOS, JHONATHAN RIO, or ROSALVA VILLALVAZO and any attorneys, agents, employees, or anyone acting or purporting to act on their behalf.
  8. The term “PLAINTIFF” and “RESPONDING PARTY” means JESSE RIOS, JHONATHAN RIO, or ROSALVA VILLALVAZO or anyone acting or purporting to act on their behalf. 
  9. The term “DEFENDANT” means OSCAR VASQUEZ, individually & dba EXPERTS OF REAL ESTATE & CAL REAL ESTATE EXPERTS, and Does 1 through 25, inclusive or anyone acting or purporting to act on their behalf. 
  10. The term “CONCERNING” means relating to, referring to, describing, evidencing, or constituting. 
  11. The term “PERSON” means any individual, corporation, partnership, limited partnership, joint venture, sole proprietorship, trust, governmental agency, or other organization recognizable at law, and its agents and employees. 
  12. The term “COMMUNICATION(S)” means any transfer of information of any kind, orally, in writing or in any other manner.  

 

  1. INSTRUCTION

Answer each question below completely.  With respect to any Interrogatory, if the response to which YOU contend is in some way “burdensome” or “oppressive,” please STATE the specific reasons for this objection.

 

III. INTERROGATORIES

  1. Please IDENTIFY the person or persons responding to these Interrogatories. Please identify in your answer each person who has provided information in connection with these interrogatory answers.
  2. DESCRIBE in detail the business relationship, if any, between Plaintiffs and Defendants.
  3. Do YOU contend that Defendants made any statement to YOU that affirmed any alleged oral agreement?
  4. If your answer to interrogatory number 3 was yes, please DESCRIBE in detail each fact upon which YOU base such contention.
  5. If your answer to interrogatory number 3 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  6. If your answer to interrogatory number 3 was yes, please IDENTIFY each WRITING relating to such contention.
  7. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 6.
  8. Do YOU contend that Defendants engaged in any conduct that affirmed any alleged oral agreement?

 

  1. If your answer to interrogatory number 8 was yes, please Describe in detail each fact upon which YOU base such contention.
  2. If your answer to interrogatory number 8 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  3. If your answer to interrogatory number 8 was yes, please IDENTIFY each WRITING relating to such contention.
  4. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 11.
  5. Do YOU contend that YOU took any action in reliance upon any words/conduct by which Defendants affirmed the alleged oral agreement?
  6. If your answer to interrogatory number 13 was yes, please DESCRIBE in detail each fact upon which YOU base such contention.
  7. If your answer to interrogatory number 13 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  8. If your answer to interrogatory number 13 was yes, please IDENTIFY each WRITING relating to such contention.
  9. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 16.
  10. Do YOU contend that YOU would suffer injury were the alleged oral contract not enforced?
  11. If your answer to interrogatory number 18 was yes, please state each fact upon which YOU base such contention.
  12. If your answer to interrogatory number 18 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  13. If your answer to interrogatory number 18 was yes, please IDENTIFY each WRITING relating to such contention.

 

  1. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 21.
  2. Do YOU contend that DEFENDANTS accepted the benefits of the alleged oral agreement?
  3. If your answer to interrogatory number 23 was yes, please DESCRIBE in detail each fact upon which YOU base such contention.
  4. If your answer to interrogatory number 23 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  5. If your answer to interrogatory number 23 was yes, please IDENTIFY each WRITING relating to such contention.
  6. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 26.
  7. Do YOU contend that DEFENDANTS would be unjustly enriched were the contract not enforced?
  8. If your answer to interrogatory number 28 was yes, please DESCRIBE in detail each fact upon which YOU base such contention.
  9. If your answer to interrogatory number 28 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
  10. If your answer to interrogatory number 28 was yes, please IDENTIFY each WRITING relating to such contention.
  11. Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 31.

 

DATED: 

       

        Respectfully Submitted

 

    Your signature
  NAME 

  Pro Se

 

CERTIFICATE OF SERVICE

 

 The undersigned does hereby certify that a true and correct copy of this Defendants’ First Set of Interrogatories was duly served upon [ENTER ADDRESSES], on [ENTER DATE].

 

  Your signature
  NAME 

  Pro Se

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