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You do not have to deny an answer. If you prefer not to answer, you can state that the interrogatory is overly broad, unduly combersome, confidential, not inclined to lead to discoverable evidence. The opposition would then have to file a motion to compel your answer and the court would have to order you to answer if there is a reasonable basis for doing so.
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Answering regarding your wife and children, that the information or documents requested are not inclined to lead to discoverable evidence. The opposition will then be forced to file a motion to compel and convince the court that these are discoverable issues.
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