Interrogatories - Defamation

Slander

[Plaintiff to Defendant]

1. Did you or agent or employee of the Defendant make the following statement about the Plaintiff on or about the date of ________, 20 __?

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   If not, please state precisely what the Defendant did, in fact, say about the Plaintiff.

2. Describe as precisely as you are able to do so, the exact substance of all of the statements, conversations and communications involving the Plaintiff on the date in question, and with respect to each statement, conversation and communication, please set forth the following information specifically and in detail:

   1. The name address, occupation and relationship to the parties of the person who made the statement.

   2. The name or names of the individual or individuals to whom the communication was directed.

   3. The date and approximate time of the communication.

   4. The location where communication was made.

   5. The context and circumstances surrounding the statement.

3. State the full name, address, telephone number and occupation of each person who witnessed the subject statements, conversations and communications.

4. State the full name, address, telephone number and occupation of each person who has knowledge of the subject statements, conversations and communications and the facts and subject matter contained within each.

5. Are you, or any agents or persons acting on your behalf, aware of any fact, observation, document, or item of evidence that, either directly or indirectly, supports the truth of the statements concerning the Plaintiff? If your answer is anything other than an unqualified “No,” then for each and every such fact, observation, document, and item of evidence, please set forth the following information separately, specifically and in detail:

   1. A detailed description of the fact, observation, document, or item of evidence, setting forth names, dates, times, places and any other information that might assist the identification and location of the subject information.

   2. The name, address, telephone number or other means of identification of each person who has possession or first hand knowledge of the subject fact, observation, document, or item of evidence, and that person’s relationships to the parties herein.

   3. The method or manner by which you obtained knowledge of this information, setting forth, names, dates, times, places and any other details that relate to the manner in which you obtained such knowledge.

   4. If the subject information is documentary, please identify the writing by stating its author, title, date, intended recipient, approximate length and a summary of its contents; also, please indicate whether or not you will, without a motion to produce, attach a copy to your answers to these interrogatories.

6. Do you contend that the Defendant was justified in making the statements pertaining to the Plaintiff? If so, then specify in detail the basis for such justification.

7. Do you contend that the Defendant was privileged in making the statements pertaining to the Plaintiff? If so, then specify in detail the basis for such privilege.

   [Defendant to Plaintiff]

1. With respect to the “statement” that forms the basis for your complaint, set forth each and every communication, word, sentence and characterization that you contend to be defamatory and untrue, and for each, set forth the following information specifically and in detail:

   1. Identify the statement, word, sentence or characterization; use quotation marks where possible.

   2. State the name, address and occupation of the person who made the statement or characterization.

   3. Set forth the date, time and place of the statement or characterization.

   4. State what you contend to be the truth or true nature of the event, issue or subject.

2. Did you ever request the Defendant to retract the alleged defamatory statement? If not, please indicate your reason for your failure to do so. If, however, your answer is anything other than an unqualified “No,” then please set forth the following information specifically and in detail:

   1. When did you demand the retraction?

   2. What mode of communication did you use to demand the retraction? State the name, address, occupation and title of the person to whom the demand was communicated.

3. State the full name...