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1 Response_to Interrogatory No. 15. 2 Objection This Interrogatory is vague and ambiguous as to the meaning of the 3 terms "safeguards", "precautions", "unexplained" and "fuel". The Interrogatory is 4 impermissibly compound C C.P. § 2030(c)(5). Subject to and without waiver of the 5 6 foregoing objections, Douglas responds to this Interrogatory as follows. During the time 71 period Douglas held an interest in the subject property, the operators of the gasoline 8 service station on the property performed a weekly reconciliation of their cash and 9 1( inventory. A Douglas Retail Sales Representative performed monthly audits. 10 Response to Interrogatory No. 16: lI 12 Objection. This Interrogatory is vague and ambiguous as to the meaning of the 13 terms "safeguards", "precautions", "unexplained" and "fuel'. The Interrogatory is 14 impermissibly compound C C.P. § 2030(c)(5). Subject to and without waiver of the 15 foregoing objections, Douglas responds to this Interrogatory as follows During the time 16 period Douglas held an interest in the subject property, the operators of the gasoline 17 service station on the property performed a weekly reconciliation of their cash and 18 19 inventory. A Douglas Retail Sales Representative performed monthly audits. 20 Response to Interrogatory No. 17: 21 Objection. This Interrogatory is vague and ambiguous as to the meaning of the 22 term "controlled". The Interrogatory is also impermissibly compound. C.C.P. 2030(c)(5) 23 Subject to and without waiver of the foregoing objections, Douglas responds to this 24 Interrogatory as follows. Douglas obtained an ownership interest in the subject property 25 26 by Grant Deed from Walter G. Burgdorf and Meta A. Burgdorf dated April 23, 1953 27 Douglas transferred its ownership interest in the property to Teachers Insurance and . 28 Annuity Association by Grant Deed dated January 3, 1958. From January 3, 1958 to 9. �-• -