Professional Documents
Culture Documents
6: Interrogatories - Fraud
[Plaintiff to Defendant]
1. Did you make the following statement [or a statement similar to the following]
to the Plaintiff on or about ____________, 20 __?
_____________________________________________
_____________________________________________
_____________________________________________
_____________________________________________
If your answer is anything other than an unqualified No, please set forth the
following information specifically and in detail:
A. State in detail the surrounding circumstances that caused you to make
the statement.
B. For each person who was present at the time the statement was made,
set forth his or her name, address, occupation and relationship to the
parties.
C. Set forth the name, address, occupation and relationship to the parties of
every person having knowledge or information of the facts and
representations contained in the statement.
D. Is the above statement true or false?
E. Did you believe that the above statement was true at the time that you
made it? If so, identify and describe with particularity every fact, writing,
item of evidence or information to support the claim that you believed the
statement to be true at the time you made it.
F. Did you intend that the Plaintiff should believe the above statement at
the time that you made it?
G. Did you intend that the Plaintiff should rely upon the above statement at
the time that you made it?
H. Did the Plaintiff rely on the above statement and take actions or make
decisions based upon the statement?213
2. Are you presently aware of any facts, evidence, documents, writings or
information of any kind that support the truth of the statement contained in the
preceding interrogatory? If your answer is anything other than an unqualified
No, please describe in detail and provide specific information with respect to
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each such fact, item of evidence, document, or writing; also, please provide the
name, address and relationship to the parties of each person possessing same.
3. Are you presently aware of any facts, evidence, documents, writings or
information of any kind that contradict the truth of the statement contained in the
preceding interrogatory? If your answer is anything other than an unqualified
No, please describe in detail and provide specific information with respect to
each such fact, item of evidence, document, writing or information; also, please
provide the name, address and relationship to the parties of each person possessing
same.
4. Did you have actual knowledge of the falsity of the subject statement before
making it?
5. Do you contend that the Plaintiff had actual knowledge of the falsity of the
subject statement before acting upon it? If so, please provide the following
information:
A. Set forth each fact, item of evidence, document, writing or information
that would support this contention; also, please provide the name, address
and relationship to the parties of each person possessing same.
B. Set forth each fact, item of evidence, document, writing or information
that would contradict this contention; also, please provide the name,
address and relationship to the parties of each person possessing same.
6. Do you contend that the Plaintiff's reliance upon your statement was not
justified? If so:
A. Set forth each fact, item of evidence, document, writing or information
that would support this contention; also, please provide the name, address
and relationship to the parties of each person possessing same.
B. Set forth each fact, item of evidence, document, writing or information
that would contradict this contention; also, please provide the name,
address and relationship to the parties of each person possessing same.
7. Do you contend that the Plaintiff could not have justifiably relied upon the
statement? If so:
A. Set forth each fact, item of evidence, document, writing or information
that would support this contention; also, please provide the name, address
and relationship to the parties of each person possessing same.
B. Set forth each fact, item of evidence, document, writing or information
that would contradict this contention; also, please provide the name,
address and relationship to the parties of each person possessing same.