THE PEOPLE OF THE STATE OF
CALIFORNIA,

Plaintiff

v.

REAL PROPERTY LOCATED IN
EL DORADO COUNTY AT 1353
CEDAR OAKS ROAD, PLACERVILLE
CALIFORNIA, ASSESSORS PARCEL
NUMBER 051-481-55-100
INCLUDING APPURTENANCES AND
ATTACHMENTS THERETO,

Defendant,

CHARLES W. HOLLAND, et al.
Real Parties In Interest.

No. PV92-0173

TO: People of the State of California
c/o El Dorado District Attorney's Office
515 Main Street
Placerville, CA 95667

These interrogatories are directed to you pursuant to Code of Civil Procedure Section 2030. You are directed to answer each of the interrogatories separately, and under oath, and serve a copy of your answers thereto on Brenda Grantland, Esq., attorney for respondent, within thirty days after service.

a. These interrogatories are continuing in character, so as to require the filing of supplemental answers if further or different information or documents are obtained prior to trial.

b. Where the name or identity of persons is requested please state his or her full name, home address, business address and telephone number, employer and job title. Where the interrogatories request the identification of documents, please identify the document by maker, date and brief description.

c. Unless otherwise indicated, these interrogatories refer to the time, place and circumstances of the occurrence mentioned in the pleadings. The term "occurrence" refers to the circumstances surrounding the seizure of property referred to in the forfeiture complaint.

d. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives and, unless privileged, his attorneys. Where answer is made by a corporation or other legal entity, state the name, address and title of the person supplying the information and making the affidavit. You should also state the source of that person's information.

e. The pronoun "you" refers to each party to whom these interrogatories and requests are directed and the persons mentioned in clause (d).

1. If you contend that claimants, Charles Holland, Edna Bettencourt and Ethel Criddle, are not innocent owners of their lien against the seized real estate, state with particularity each item of evidence upon which you intend to rely to support that contention.

2. For each item you list in response to interrogatory number 1, identify the documents and witnesses through which you intend to establish that fact.

3. If you contend that claimants' foreclosure of their lien was invalid, state with particularity the basis for that contention and state every item of evidence upon which you intend to rely to support that contention.

4. For each item you list in response to interrogatory number 3, identify the documents and witnesses through which you intend to establish that fact.

5. State with particularity what efforts the People of California have made to move this forfeiture case forward since the filing of the forfeiture complaint on March 13, 1992.

6. With regard to interrogatory number 5 above, if the People contend that the delay since the filing of the forfeiture complaint is due to ongoing investigation, list the dates of all interviews of witnesses in the past two years, and the names and addresses of the witnesses interviewed.

7. With regard to the underlying criminal prosecution of Roy and Linda Clayton, state the outcome of the criminal prosecution, including the date of sentencing and the sentence(s) imposed.

8. State the names, work and home addresses and phone numbers of all persons whom you intend to call as witnesses in this action. As to each, specify the substance of the matters to which he will testify and the basis for such witness's testimony.

9. Identify each document in the government's possession, other than the documents produced by claimants in discovery, which contains any information or which pertains in any way to the occurrence. The term "document" refers to any writing, drawing, graph, chart, photograph, tape recordings, transcripts, and other data compilations from which information can be obtained and translated, if necessary, into reasonably usable form. Each "document" should be identified by a brief description, author or maker, date and subject matter.
 

Dated:
 

I hereby certify that a copy of the foregoing was served, by mail, upon Eric Schleuter, Assistant District Attorney, 515 Main Street, Placerville, CA 95667, this _____________ day of ______________, 1996.