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:

   1. State in detail the surrounding circumstances that caused you to make the statement.

   2. 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.

   3. 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.

   4. Is the above statement true or false?

   5. 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.

   6. Did you intend that the Plaintiff should believe the above statement at the time that you made it?

   7. Did you intend that the Plaintiff should rely upon the above statement at the time that you made it?

   8. Did the Plaintiff rely on the above statement and take actions or make decisions based upon the statement?¹

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 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...