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David M. Gurewitz/State Bar No. 76641 1

David M. Gurewitz/State Bar No. 76641 1

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Published by: jmiedecke on Feb 08, 2010
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02/08/2010

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12345678910111213141516171819202122232425262728David M. Gurewitz/State Bar No. 76641Attorney at Law4675 Wailapa RoadP. O. Box 1267Kilauea, Hawaii 96754Telephone: (310) 545-5696Fax: (808) 828-6299Attorney for Defendant
SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF ORANGECENTRAL JUSTICE CENTER 
REGENCY CENTERS, L.P. a Delawarelimited partnership,Plaintiff,-vs-JOY A. MIEDECKE, individually and dbaPUDDLEDUCKS; and DOES 1 through 20,inclusive,Defendants ___________________________________  _ )))))))))))))CASE NO. 30-2008-00108237-CU-BC-CJCRESPONSE OF JOY A. MIEDECKE TOFORM INTERROGATORIES(SET NO. ONE)PROPOUNDING PARTY:Plaintif
REGENCY CENTERS, L.P.RESPONDING PARTY:Defendant JOY A. MIEDECKE
SET NO: ONEDefendant Joy A. Miedecke (“Responding Party”) responds to Plaintiff RegencyCenters, L.P. (“Propounding Party”) Form Interrogatories (Set No. One) as follows:GENERAL OBJECTIONS AND RESPONSES1.To the extent that any specific Interrogatory may be construed to seeinformation which is protected from disclosure by the attorney-client privilege or the attorney
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Responses to Form Interrogatories
 
12345678910111213141516171819202122232425262728work-product doctrine or any other privilege, rule or doctrine, Responding Party objects to theInterrogatory and will not provide the information.2.Insofar as any specific Interrogatory may be construed to seek information whichis not within the possession, custody or control of Responding Party, Responding Party objectsto the Interrogatory.3.Responding Party has not completed its investigation of the facts relating to thiscase, has not completed discovery in this action and has not completed preparation for trial.Accordingly, all responses contained herein are without prejudice to Responding Party’s rightto produce evidence of any subsequently discovered facts and to produce expert testimony onany issue. Furthermore, the answers contained herein may be based in whole or in part onhearsay data and other information inadmissible at the time of trial, although discoverable.4.All responses contained herein are based only upon such information anddocuments which are presently available to and specifically known to Responding Party anddisclose only those contentions which presently occur to it. It is anticipated that furthediscovery, independent investigation, legal research and analysis will supply additional facts,add meaning to the known facts, as well as establish entirely new factual conclusions and legalcontentions, all of which may lead to substantial additions to, changes in and variations fromthe contentions herein set forth.5.The following Interrogatory Responses are given without prejudice toResponding Party’s right to produce evidence of any fact or facts which may be recalled later.Responding Party accordingly reserves the right to change any and all responses herein asadditional facts are ascertained, analyses are made, legal research is completed and contentionsare made.6.The responses contained herein are made in a good faith effort to supply as muchfactual information and as much specification of legal contentions as is presently known butshould in no way be to Responding Party’s prejudice in relation to further discovery, research
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Responses to Form Interrogatories
 
12345678910111213141516171819202122232425262728or analysis.7.Each Response is also subject to all appropriate objections (including, withoutlimitation, objections concerning competency, relevancy, materiality, propriety andadmissibility) which would require the exclusion of the responses if such responses were to beintroduced at any hearing or trial of this matter. All such objections and grounds for objectionsinvolving or relating to the matters raised herein are reserved and may be introduced at the timeof trial or other hearing.8.Responding Party objects to each and every interrogatory to the extent that itcalls for the disclosure of information protected by the attorney-client privilege, attorney work  product doctrine or other applicable privilege, and Responding Party’s responses herein shallnot be deemed to be a waiver of any such privilege or protection.9.Responding Party objects to each and every Interrogatory to the extent that itcalls for information that is not relevant to the subject matter of this action and/or reasonablycalculated to lead to the discovery of admissible evidence.10.Responding Party objects to each and every Interrogatory to the extent that aresponse would necessitate the preparation of a compilation, abstract, audit or summary of, or from documents in Responding Party’s possession, custody or control (including those produced in this litigation) and Responding Party hereby exercises its option, pursuant toCalifornia Code of Civil Procedure §2030.230 to specify those documents from which ananswer may be derived or ascertained.11.Responding Party objects to each and every Interrogatory to the extent that itseeks confidential or proprietary business information.12.Responding Party objects to each and every Interrogatory to the extent that itseeks the disclosure of information, communications and/or documents in violation of Responding Party’s, its current or former employees’ or third parties’ rights of privacy. Anyresponses herein shall not be deemed to be a waiver of Responding Party’s or any third party’s
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Responses to Form Interrogatories

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