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This Discovery Interrogatories from Defendant to Plaintiff with Production Requests is a sample of interrogatories for the Defendant in a Divorce action to ask the Plaintiff. It also includes request for production of documents. You should only use this form as a guide and delete questions not relevant to your case, as well as add questions you or your client wants to ask the Plaintiff based upon the facts of your case. It also includes the separate Notice of Filing of Discovery to be filed with the Court Clerk.
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