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Lucy, Esq.
Lucy, Esq., Attorney
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I am serving interrogatories and request to the Defendant.

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I am serving interrogatories and request to the Defendant. I know attorneys try to not answer as much as possible and will claim a single question or request is more than one. Please consider this question and let me know if it is a single question:

1. If you contend that any additional part of the property, or it’s fixtures and/or apparatuses were damaged by Plaintiffs misuse, waste or neglect, specifically state what was damaged and state with particularity the facts upon which you base your contentions.

Also, let me know if the follow request for admission is a single admission:

1. Admit you are responsible for maintenance and repair of all major appliances, plumbing, range, heating, apparatus, and electric and gas fixtures whenever damage thereto did not result from misuse, waste or neglect by the Plaintiffs or Plaintiffs employee, family, agent, or visitor.

My name is XXXXX XXXXX I'd be happy to answer your questions today.

That interrogatory can be reasonably read as one question. They might try to argue that "state with particularity" is a separate question or subpart. The only way to break it up would be to ask them to state what items were damaged in one question and then state something like "With regard to each item listed under #1, state with particularity..."

The admission looks like it's a restating of the statute regarding a landlord's obligation to maintain rental premises. That is a single request, asking the landlord to acknowledge the law, essentially.

If you have any questions or concerns about what I've written, please reply so that I may address them. It's important to me that you are 100% satisfied with the service I provide. Otherwise, please rate my service positively so that I get credit for answering your question. Thank you.
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Customer: replied 3 years ago.

Hi Lucy, the judge approved 10 interrog, 10 admissions and 10 request for production. Is the list of 10 interrogatories a combination of the pattern and non-pattern? Meaning I don't get 10 pattern plus 10 non-pattern, only a total of 10 split between the two. Are their any pattern interrogatories that are mandatory, most of the pattern ones do not apply to the case? And, do I have to send all 30 at the same time or can I send some now and some later?


Optional Information:
Country relating to Question: United States
State (if USA): Colorado

If the judge is only allowing 10 interrogatories and did not specify otherwise, that would be a combination of both pattern and non-pattern. You are not required to ask for any information that is not relevant to your case.

Ordinarily, a party can send interrogatories, requests for admission and requests for production of document separately. However, if the judge specifically issued on order saying that's what you get, and he didn't say that you can split it up, you may have to send it all at once. Review the order, or look at the docket if the order wasn't written, to see what it says.
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