RESTRAINT OF TRADE
Shylock v. Antonio
Plaintiff’s First Interrogatories
Interrogatory No. 4: If you prick us, do we not bleed? If you tickle us, do we not laugh? If you poison us, do we not die? And if you wrong us, shall we not revenge?
Answer: Defendant objects to Interrogatory No. 4 on the ground that whether pricking, tickling, poisoning, or wronging is the proximate cause of bleeding, laughing, death, or the seeking of revenge, respectively, can only be established through expert testimony. Because Plaintiff has failed to timely disclose expert(s) and submit expert reports covering these subjects pursuant to Federal Rule of Civil Procedure 26, Plaintiff should be barred from presenting evidence on these points, and Defendant has no obligation to respond to this interrogatory. Subject to and without waiving this objection, Defendant denies that he pricked, tickled, poisoned or in any way wronged Plaintiff. Defendant further states that it has not yet determined who, if anyone, it intends to use as expert witnesses, but reserves the right to designate expert(s) in accordance with Rule 26.
CIVIL RIGHTS/WRONGFUL DEATH
Estate of Julius Caesar v. Cassius, Casca,
Brutus, et al.
Interrogatory No. 14: Et tu, Brute?
Answer: Defendant Brutus objects to Interrogatory No. 14 on the ground that it is vague and ambiguous. Furthermore, to the extent that the interrogatory seeks to establish the actions of defendant Brutus as a proximate cause of Caesar’s death, defendant asserts that the interrogatory is beyond the scope of interrogatories and is a question of fact to be determined by jury.
Hamlet v. Hamlet
Interrogatory No. 1: To be, or not to be: that is the question: Whether ’tis nobler in the mind to suffer the slings and arrows of outrageous fortune or to take arms against a sea of troubles, and by opposing end them?
Answer: Defendant objects to Interrogatory No. 1 on the ground that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence to the extent it seeks to answer one of life’s unanswerable metaphysical questions. Defendant further objects on the ground that Int. No. 1 is too vague and ambiguous to permit a meaningful response due to the variation in the type of slings and arrows, and the unknown skill with which outrageous fortune may wield such.
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Capulet v. Montague
Interrogatory No. 4: O Romeo, Romeo! Wherefore art thou Romeo?
Answer: Defendant objects. Defendant, in his Answer to Plaintiff’s First Amended Complaint, has already conceded the court has in personam jurisdiction over him, and he has also availed himself of the Verona courts in filing his Counterclaim and Third-Party Counterclaim (see also interrogatories attached below). Any further information regarding Defendant’s location is therefore irrelevant. What is more, Plaintiff and the court are aware that one of Defendant’s allegations in his Third-Party Counterclaim lawsuit is that members of Plaintiff’s family have threatened his life and intend to do him bodily harm with swords. Defendant considers efforts, such as this question, to ascertain his whereabouts to be related to the illegal purpose of causing him bodily harm, rather than for any legitimate purposes relating to this (or Defendant’s) lawsuit. Accordingly, Defendant will seek sanctions against Plaintiff’s attorneys for any further abuses of the discovery process.
VARIOUS INTENTIONAL TORTS
Montague v. Capulet, et al.
Interrogatory No. 25: But, soft! What light through yonder window breaks?
Answer: The referred-to light is a product of Star-crossed Industries, Ltd., a division of The Capulet Co., Inc. More specifically, the no-glare, artificial light was generated by the new Star-crossed Home Artificial Kerosene Emission System™, patent pending; the low-energy light produced is soft on the eyes and perfect for reading or any other home activity. Defendant objects to disclosing more detailed information about the light-any other information would be relevant to neither the Counterclaim nor the Third-Party Counterclaim, and, more important, it would require the disclosure of protected trade secrets. Counterclaim Defendant directs Counterclaim Plaintiff to direct any further inquiries regarding the referred-to light to counsel for The Capulet Co., Inc.