Document wgd38jKxMRJnVqg70MVpj2y26
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(c) Specifically identify any eye-witness who has
information of any kind concerning such a 2 :! contention.
3 ANSWER: Witnesses and exhibits intended to be used at trial will be produced vtfien developed consistent with pretrial orders of the court. These are not currently available.
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10 5.31 Do you contend that the claim of the plaintiff is ii .jbarred by improper venue and/or lack of jurisdiction?
12 ANSWER: No.
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16 5.32 If your answer to the preceding interrogatory is in
17 ' the affirmative, indicate the reason(s) why you assert there is
18 rimproper venue and/or lack of jurisdiction.
19 i: ANSWER:
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see 5.31 above.
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26 PLAINTIFF'S FIRST INTERROGS., ETC. - 125
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