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Subject to and without waiving Defendant s General Objections Defendant responds as follows INTERROGATORY NO. 1 Please identify all persons who have any knowledge or information about any of the allegations claims facts or other matters asserted in the Complaint in this lawsuit in Your Answer or other response to the Complaint in this lawsuit or in Your Counterclaim. Defendant John Doe accordingly reserves the right to supplement change or modify these responses to Plaintiff s Interrogatories...
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