Re: Partition Action - Interrogatories

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On 7/23/07, Chandra M. Arkema wrote:
> We represent the plaintiff in a partition action. To make
> a long story short, he purchased a home with his girlfriend
> when they had a child together. He paid for the
> downpayment and the mortgage for a three years. They broke
> up and he moved out and discontinued contributing to the
> mortgage. He has not lived there since 1999. A trial date
> has been scheduled. We would like to send rogs to the
> defendant, but I'm not sure which questions would be most
> relevant. We are most concerned about any experts or other
> witnesses they intend to use. Do any of you have
> a "standard" set of rogs you use for this type of action?
> If you would be willing to share them with me, that would
> be great! Thanks!!

I'm also working on a similar case and trying to draft
discovery. Did you ever get any responses that you can share?