Section 2572.1Damage to Reputation
1.Do YOU contend that YOU suffered any injury to your reputation as a result of [here describe conduct that allegedly invaded plaintiff’s privacy]?
2.If your answer to interrogatory number 1 was yes, please state each fact upon which YOU base such contention.
3.If your answer to interrogatory number 1 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
4.If your answer to interrogatory number 1 was yes, please IDENTIFY each WRITING relating to such contention.
5.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 4.
6.Please IDENTIFY each PERSON who can compare your reputation before and after [here describe conduct that allegedly invaded plaintiff’s privacy].
7.Do YOU contend that YOU suffered injury to your standing in the community as a result of [here describe conduct that allegedly invaded plaintiff’s privacy]?
8.If your answer to interrogatory number 7 was yes, please state each fact upon which YOU base such contention.
9.If your answer to interrogatory number 7 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
10.If your answer to interrogatory number 7 was yes, please IDENTIFY each WRITING relating to such contention.
11.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 10.
12.Please IDENTIFY each PERSON who can compare your standing in the community before and after [here describe conduct that allegedly invaded plaintiff’s privacy].
13.Do YOU contend that YOU suffered injury to your business reputation as a result of [here describe conduct that allegedly invaded plaintiff’s privacy]?
14.If your answer to interrogatory number 13 was yes, please state each fact upon which YOU base such contention.
15.If your answer to interrogatory number 13 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
16.If your answer to interrogatory number 13 was yes, please IDENTIFY each WRITING relating to such contention.
17.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 16.
18.Please IDENTIFY each PERSON who can compare your business reputation in the community before and after [here describe conduct that allegedly invaded plaintiff’s privacy].