Plaintiff response to form interrogatories re GGU -- Golden Gate University (GGU) lawsuit re misrepresentation

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Date Posted: 22:08:31 09/26/04 Sun
Author: Mike
Subject: Plaintiff response to form interrogatories re GGU

9.1 (a) Students who visit GGU�s web-site are being misled to believe that 14 million people visit the campus when, in fact, 14 million people do not visit the campus. This fraudulent activity on the part of GGU causes individuals to wish to visit and enroll at the university under false pretenses. Thus, students and prospective students suffer monetary loses which in turn causes GGU to become unfairly enriched.
(b) It occurs from the date GGU posted the false statement to the present.
(c) The amount of damages, admittedly, is difficult for Plaintiff to calculate at the present time.
(d) GGU can review the roster of the students enrolled at the San Francisco campus to determine to whom an obligation has been incurred.
9.2 GGU has possession or equal access to all responsive documents.
10.1 Plaintiff objects to this interrogatory because it seeks information that is irrelevant to this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
10.2 Plaintiff objects to this interrogatory because it seeks information that is irrelevant to this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
10.3 Plaintiff objects to this interrogatory because it seeks information that is irrelevant to this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
11.1 Plaintiff objects to this interrogatory because it seeks information that is irrelevant to this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.
12.1 Sharon Levy: (925) 286-3462; Jeff Bialik, Dr. Philip Friedman, and Joseph Burgess, whose contact information is in Defendants� possession.
12.2 Plaintiff objects to this interrogatory because the term �interviewed� is vague and ambiguous. Subject to and without waiving the foregoing, Plaintiff answers as follows: No, unless the term �interviewed� is defined to include depositions.
12.3 Plaintiff objects to this interrogatory because the term �written or recorded statement� is vague and ambiguous. Subject to and without waiving the foregoing, Plaintiff answers as follows: No, unless the term �written or recorded statement� is defined to include depositions.
12.6 Plaintiff objects to this interrogatory because the term �report� is vague and ambiguous. Subject to and without waiving the foregoing, Plaintiff answers as follows: No, unless the term �report� is defined to include depositions.
13.1 No.
13.2 Not applicable.
14.1 Yes. GGU, Philip Freidman, and Jeff Bialik violated the statutes which are mentioned in the first amended complaint filed in this matter and which are being incorporated by reference to this response.
14.2 Plaintiff objects to this interrogatory because it seeks information that is irrelevant to this litigation and is not reasonably calculated to lead to the discovery of admissible evidence.

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