Section 2542.1False Light Requiring Reference to Extrinsic Facts
1.Do YOU contend that [here identify matter published or disclosed] did not [state, imply, etc.] that plaintiff had committed the crime of [here specify criminal act]?
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.Do YOU contend that [here identify matter published or disclosed] did not [state, imply, etc.] that plaintiff had engaged in dishonest conduct?
7.If your answer to interrogatory number 6 was yes, please state each fact upon which YOU base such contention.
8.If your answer to interrogatory number 6 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
9.If your answer to interrogatory number 6 was yes, please IDENTIFY each WRITING relating to such contention.
10.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 9.
11.Do YOU contend that [here identify matter published or disclosed] did not [state or imply, etc.] that plaintiff [here set forth false suggestion or implication]?
12.If your answer to interrogatory number 11 was yes, please state each fact upon which YOU base such contention.
13.If your answer to interrogatory number 11 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
14.If your answer to interrogatory number 11 was yes, please IDENTIFY each WRITING relating to such contention.
15.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 14.
16.Do YOU contend that knowledge of extrinsic facts was necessary before [here identify the publication or disclosure] could be understood to portray plaintiff in a false light in the public eye?
17.If your answer to interrogatory number 16 was yes, please state each fact upon which YOU base such contention.
18.If your answer to interrogatory number 16 was yes, please IDENTIFY each PERSON who has knowledge of any fact relating to such contention.
19.If your answer to interrogatory number 16 was yes, please IDENTIFY each WRITING relating to such contention.
20.Please IDENTIFY the present CUSTODIAN of each WRITING identified in your answer to interrogatory number 19.