Objections to interrogatories california. 1 checked when you use Request for Admissions.

For years the Courts had found that the Form Interrogatories were objection proof as to form with minor exceptions. 1, as follows: "Form Interrogatory 15. v. Most requests should be answered, even if an objection is stated. 010-2030. Court 408 F. Form interrogatories are an easy way for parties to ask common questions by simply checking the boxes for the questions they wish to ask. Discovery Referee, Special Master, and Mediator 1-650-571-1011 969G Edgewater Blvd. California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. 090] 2030. 1 State the name, ADDRESS, and telephone number of each individual Oct 8, 2019 · In fact, boilerplate general objections are sanctionable in California per Korea Data Systems Co. 12. 060, subdivision (d) because each was not “full and complete in itself” was interposed to interrogatory Nos. 210 et. Answers and objections are served together, so that a response to each interrogatory is encouraged, and any failure to respond is easily noted. 710), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. It contains practical guidance, drafting notes, and optional paragraphs. [CCP § 2030. 010 - General Information on Interrogatories. The objection must include an explanation as to why the request lacks relevance. Privileges must be asserted. Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2030. Jan 1, 2023 · (d) Each interrogatory shall be full and complete in and of itself. 090 2030. The Information Is Public and Available to Everyone . While seemingly still a modern marvel, social media as we know it today is actually entering its teenage years. (2) An exercise of the option to produce documents under Section 2030. They do not change existing law relating to interrogatories, nor do they affect the answering party’s right to assert any privilege or make any objection. 7 I am planning to object on privacy grounds, and not reasonably calculated to lead to admissible evidence. Colo. The case of Vidal Sassoon, Inc. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. 1- 16. Section 2030. Jul 14, 2010 · See California Code of Civil Procedure §§2030. California Practice Guide: Civil Procedure Before Trial KFC 995 . Understanding Form Interrogatories in California: — Definition and purpose of Form Interrogatories — How they are served and responded t— - Their significance in the discovery phase of lawsuits 2. 3d 681 at 685 (Pre There is almost no risk in stating an objection if the request is answered any way. 250 and 2033. 340, 351-52 (1978). 1 and 6. 1 (an “interrogatory” is just a question) is the most important interrogatory to serve on your opposing party in a lawsuit. RESPONSES TO INTERROGATORIES Interrogatory No. 1 checked when you use Request for Admissions. 270(a) explains, Jan 12, 2010 · Instead of answering, may serve objections. 010(a). S. 0, 2. Los Angeles, California 90049 . right to privacy in california and federal discovery introduction: Consider using Form Interrogatories - General (form DISC-001) with interrogatory 17. 2 through 5, 7 through 16, 18, 20, 22 and 23. 210(a), 2030. CCP §§ 2030. g. at *12-13. (1) An answer to a particular interrogatory is evasive or incomplete. The court then These cases indicate that the bare claim of previous deposition is insufficient as an objection to an interrogatory. If a question is checked, your spouse wants you to answer it. Telephone An objection to the particular interrogatory. postmacro2 (do not delete) 6/10/2013 9:36 am ending evasive responses to written discovery: a guide for properly responding (and objecting) to interrogatories and document requests under the texas discovery rules Jul 13, 2024 · (a) Service of an answer or objection. A. 240(b). May 27, 2019 · One case California litigators must have in their arsenal is Rifkind v. 300. These General Objections and Limitations apply to each of Plaintiffs’ Discovery Requests as though restated in full in response thereto. The law repudiates these objections, courts despise them, and litigants pay (literally and figuratively) for them. , Inc. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Superior Court (1983) 147 Cal. Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Smithfield Foods, Inc. 010 - 2030. W45. This template illustrates objections and responses to interrogatories that may be used in a California superior court civil action. The first is that you cannot submit the same interrogatory twice: if you don't like the answer (or lack of an answer) you got the first time, you had better move to compel — do not ask the question again. 300(c), 2031. Here, we cover a wide range of possible objections both attorneys and experts should review before deposition or trial. [9] To suffice as a valid objection such claim must be supported by some showing (or, as a minimum, some claim) that the requirement of a reply would be unjust or inequitable. seq require specific statements in your response. Some of the valid grounds for objecting to interrogatories are: If a party to whom interrogatories are directed fails to serve a timely response, the following rules apply: (a) The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030. 230, as well as any objection to the interrogatories, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018. 010, 2030. opn. Code Civ. Responding parties even use garbage objections to Form Interrogatories which were drafted by the California See Cal. Deposition Objections. App. 4, 8. Within twenty days after service of interrogatories, the party upon whom they are served shall serve upon each of the parties a copy of the answer to each interrogatory, except one to which the party objects, in which event the reasons for the objection shall be stated with reasonable particularity. (a) Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. Sep 23, 2009 · The objection to the term “economic damages” as vague and ambiguous was interposed to interrogatory Nos. §§ 2025. §§ 2030. Jan 1, 2023 · (a) Any party may obtain discovery within the scope delimited by Chapter 2 (commencing with Section 2017. 060 (d) as not being 'complete in of itself' because it refers to [Movant's] denials and affirmative defenses in [Movant's] pleadings without setting them forth in the Interrogatory. 2d 629, 639 (Tex. By mastering these rules and best practices, California atorneys, like yourself, can streamline discovery process, gain confidence when drafting or responding to interrogatories, and spend less time researching procedure and more time creating beter client outcomes. Sanders, 437 U. Read the code on FindLaw An objection to an interrogatory is without merit or too general. LEXIS 78024, at *3-6 (E. wise. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order Aug 15, 2020 · “Blockbuster interrogatories constitute an unduly burdensome request as a matter of law and are an abuse of the discovery process. 2010) §6:100. [#], Defendant has asserted objections as to only a portion of these interrogatories and has failed Feb 13, 2016 · Objections may be proper, but must be timely served, otherwise waived. See CEB, California Civil Discovery Practice (4th ed. The trial court denied plaintiff's motion to compel on the ground that the questions "call for a legal theory of the facts [and] should be accomplished by means of written interrogatories wherein tion. 13; California Deposition and Discovery Practice KFC1020 . . 5, 2. Vague and ambiguous questions b. This Standard Document has integrated notes with important tips on how to draft the response, including the case caption, answers, objections, responses exercising the option to produce documents, signature block, and verification. Oct 20, 2020 · In other words, objections to interrogatories must be specific, non-boilerplate, and supported by particularized facts where necessary to demonstrate the basis for the objection. " Nov 14, 2019 · The purpose of the “meet and confer” requirements set forth in C. Unless he applies for a protective order, he is required to serve answers or objections in response to the interrogatories, subject to the sanctions provided in Rule 37(d). Such answers shall respond to the written interrogatories; or, if any interrogatory be deemed objectionable, the objections thereto may be stated by the party addressed in lieu of response. Counsel defending depositions will often lodge Rifkind objections to justify an instruction that the deponent not answer a question. , Suite 702 Los Angeles, California 90049 [DEFENDANT(S)] Tel: 310. 25 Million Award Employment Claims in the Coronavirus Era Discovery of Litigation Funding “Plaintiff timely served updated verified responses to Form Interrogatories, Set #1, #6. Responses to requests for production and interrogatories are often littered with trite objections like “Objection: overbroad, irrelevant, privileged”—objections low on detail and high on obstruction. Sep 9, 2014 · (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. Key Points to be Covered: 1. , opinion, hearsay, assumes facts not in evidence If you receive Form Interrogatories (form FL-145) it means your spouse is asking you to answer questions or provide documents. Superior Court , 22 Cal. 480, 2030. 3d 1142, 2005 WL 1175 922 (9th Cir. F56. No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17 (commencing with Section 2033. Proc. , Civil Action No. Your response for each request must include either an agreement to comply, a representation of your ability to reply, or an objection to all or part of the request. Be aware that a party that disagrees with you may meet and confer then file a motion, which can be particularly stressful as they would request not only an order to make the party respond to the disputed discovery but also the motion may seek recovery of attorney's fees for having to file the motion. As shown in Plaintiff’s Separate Statement, in the case of Interrogatory Nos. Responses to interrogatories are due within 30 days (5 days for unlawful detainer actions) if the interrogatories were personally served, 35 days if the interrogatories were served by mail, and 30 days plus 2 court days if the interrogatories were served by express mail or Jun 30, 2021 · After acknowledging that HealthEdge must “eventually respond to these requests,” the court upheld HealthEdge’s objection – pointing to Federal Rule of Civil Procedure 33(a)(2)’s provision allowing the court to “order that such discovery requests not be responded to until later in the litigation. 230. The form is a list of questions with checkboxes – called form interrogatories. Superior Court (1997) 51 Cal. California Discovery Citations KFC 1020 . 010), by propounding to any other party to the action written interrogatories to be answered under oath. SELARZ (State Bar No. ‍ Categories of Discovery Objections ‍Start your objections with the phrase: "Plaintiff/Defendant objects to this request/interrogatory on the ground that . pdf document contains the legal authorities for dozens of common evidentiary objections in an easy-to-read chart. Your options are (1) object and don't answer some or all of the questions, and make them push forward to compel discovery; (2) respond; (3) move for a protective order limiting the discovery, likely on an ex parte basis; and (4) move to continue the MSJ if Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. U. ). June 16, 2015), plaintiff submitted contention interrogatories asking defendant to “state all facts” on which the defendant based certain employee classifications pursuant to the California Labor Code and other regulations. Cal. One famous case where this issue arose is Oppenheimer Fund, Inc. The second is, if you are going to A Form Interrogatory is the easiest tool to use for discovery. 010) and 3 (commencing with Section 2017. P. 300 is a legal action taken when a party fails to serve timely responses to discovery requests, such as interrogatories or requests for production. G674. OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. As the responding party, you must either answer the interrogatory under oath or provide a specific objection. The court Aug 14, 2015 · DEFENDANT'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES RELATING TO JURISDICTIONAL DISCOVERY. §§ 2017. Apr 30, 2021 · You Poetic, Noble Land Mermaid: A Celebration of “Galentine’s Day” A Tell-All Article on Written Discovery Objections The Wave of Recent COVID-19 Litigation and Trends to Watch For How to Avoid Appearing as a Cat and Other Helpful Virtual Deposition Tips California Court Refuses to Reduce a $9. Interrogatories are a frequently-used discovery device, consisting of written questions propounded by one party to another. App. 210(a)(3)] Alternative to protective order TIP Don’t object to form (e. Apr 21, 2009 · A party may propound 35 special interrogatories and any additional number of official form interrogatories. (b Mar 1, 2018 · To maximize the likelihood of obtaining requested social media evidence, carefully craft interrogatories and requests for production to encompass relevant and reasonably calculated materials. Aug 31, 2011 · Two years into a complex case you are served with Specially Prepared Interrogatories Set #5– Interrogatories 152-185, Requests for Admissions Set #3–Requests #57-91, Form Interrogatories Set #4 with 17. 460) PROPER OBJECTIONS: Calls for Contention: Rifkind v. If the interrogatories are not objected to, each of the questions must be separately answered under oath. objections. 4th 390 Boilerplate general objections are sanctionable in California per Korea Data Systems Co. 0 Investigation—General Series, reads as follows: 12. Other than procedural I have personal reasons to stand by these objection due to harassing and intrusive conduct of the defense calculated to harass and force dismissal. Defendant served Judicial Council Form Interrogatories which included Interrogatory No. Their use was usually the first volley in the discovery battle. 030(a)(2) and 2030. (3) An objection to the particular interrogatory. —Texarkana 1997, writ denied). It's a set of questions on a standard form. Failure to timely raise an objection to any interrogatory, request for admission or request for production of documents waives the objection. If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient California Civil Litigation and Discovery KFC 995 . 230, as well as any objection to the interrogatories, including one based on privilege or on the protection for work product under Chapter 4 (commencing (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party’s right to assert any privilege or make any objection. 2005) [trial court affirmed in holding boilerplate May 27, 2024 · Privilege objections can be made on a number of grounds of recognized legal privilege, including: Spousal privilege; Attorney-client privilege; Doctor-patient privilege; Constitutional privilege (such as Fifth Amendment privilege) Privilege objections are a good instance of how deposition objections can be key to future legal proceedings. 290 was for the lawyers to revisit their position, and in good faith, discuss a resolution in order to avoid unnecessary discovery motions. 1 (RFA #5) pursuant to a Supplemental Interrogatory request. 8685 • Fax: 310. C. 070. (b) In the first paragraph of the response immediately below the title of the case, there shall appear the identity of the responding party, the set number, and the identity of the propounding party. 1. That means, for example, Responses to Interrogatories Superior Court of California San Diego Timing 30 Days, Extension For Manner of Service. If an objection is based on a claim of privilege, the particular A sample response to interrogatories that counsel may use in a California unlimited civil action. 220(b). ” Id. Propounding Interrogatories CODE OF CIVIL PROCEDURE SECTION 2030. (3) An objection to an interrogatory is without merit or too general. ” Even though several interrogatories may be objectionable on the same ground they may not be objected to as a group. Superior Court (1994) 22 CA 4th 1255. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. 010), by Sep 6, 2021 · A proper objection might include the following language: OBJECTION: The information requested is equally available to the requesting party. 651. --Pacific-Healthcare (2007) 148 Cal. In this situation, one party objected to Form Interrogatory 15. The interrogatories on page 2 of this form are intended to provide for the exchange of relevant information without unreasonable expense to the answering party. The "rule of 35" means almost nothing in a general civil case in California state Court. Interrogatories should not require a party to provide a narrative account of his case. See Cal. Romero v. 15 Electronic Access: On the Law Library’s computers, using OnLaw. (2) If the court does not specifically rule on the objection raised by a party, the objection is presumed overruled. California Forms of Pleading and Practice KFC 1010 . 210(a) and CCP §2030. Whittle, 947 S. 250 - Signing responses under oath (a) The party to whom the interrogatories are directed shall sign the response under oath unless the response contains only objections. May 3, 2006). An expert’s deposition is an important part of their overall testimony. If not stated in time, court can waive the objection or excuse the delay if there is good cause. Nov 2, 2007 · Just a few hours after posting my white paper on written discovery, I encountered this post at Storm's Employment Law, criticizing the abuse of form interrogatories and raising the issue whether these interrogatories -- approved by the California Judicial Council Mar 7, 2013 · Folsom, California 95630 Tel: (916) 353-1084 Fax: (916) 353-1085 Plaintiffs Responses to Form Interrogatories propounded by Intervenors, Set One Jan 1, 2023 · (a) The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030. 287555) dselarz@selarzlaw. 1. 020 - Timing For Serving Interrogatories. 010), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. This 10- page . Read the code on FindLaw In addition to the number of interrogatories permitted by Sections By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. 010. 310(b), 2032. 450(b)(2), 2025. , Suite 702 . Each objection must be stated separately (no objections to entire set), and must bear the same number or letter as the interrogatory to which it is directed. Aug 24, 2021 · There are two important but subtle rules of civil discovery that come to the surface in Estate of Huang (D2d4 Aug. 60 and 61 Electronic Access: On the Law Library’s computers, using Lexis Advance. To the extent Defendant asserts objections to individual requests, those objections shall apply equally to any subparts of the request. This requires the other side to provide additional information about any Request they do not admit, including the facts supporting their denial, the identity of the persons with knowledge of those facts, and the 10. Objecting to interrogatories. Discovery disputes often involve the use of form interrogatories. , the identity of “all” persons or “every” person having knowledge of relevant facts. Repeatedly requesting the same information may in fact be objectionable, but the situation is not as clear cut as it may seem. While the authorities cited are to Federal and California law, these objections apply to most jurisdictions and can also be used to object to deposition notices. C35 Chap. And the law requires they answer it fully and completely. This PDF doc contains objections in court cheat sheet. com . com It is also possible to request discovery objections based on the grounds that the request is irrelevant. 010). W. If your case is an unlimited civil case (more than $35,000) form interrogatories are not counted against the amount of discovery you may ask. Objections to from interrogatories #2. 300(b), 2031. civil litigation. 710). ” There’s no statutory provision for objecting on the ground that interrogatories are “too broad,” but courts use this objection to refer to interrogatories that request, e. Code of Civil Procedure § 2030. 1:14-cv-00524 JLT, 2015 U. 8681 SELARZ LAW CORP. The objection that the interrogatories violated section 2030. The Code of Civil Procedure § 2030. 4th 1257 (1994). II. ” CCP § 2030. (b) If that party is a public or private corporation, or a partnership, association, or governmental agency, one of its officers or agents shall sign the response Oct 30, 2020 · Overbroad or “shotgun interrogatories. Jan 12, 2023 · From discovery to trial, there are several occasions when objections to an expert’s opinion are proper. (See Kainz v. Ltd. “If an interrogatory cannot be answered completely, it shall be answered to the extent possible. The plaintiff's attorney asked him essentially the same questions at deposition, and was met by an objection and refusal to answer. , Case No. If you are properly served with interrogatories, you are generally under a duty to respond to each question separately, under oath, and within 30 days (see CCP §2030. It may seem obvious, but contention interrogatories are still interrogatories; thus, the defense still has to comply with all of the duties inherent in answering any interrogatories. Common ones in most civil cases are: Form Interrogatories – General (form DISC-001) (for use in unlimited civil cases) A must-have for any trial binder. 1 checked and Requests for Production of Documents, Set #5–Requests 180-222. , Suite 345 Foster City, CA 94404 phone: (650)571-1011 fax: (650)571-0793 klgallo@discoveryreferee. 1, which is under the 12. " (1) An answer to a particular interrogatory is evasive or incomplete. Unless the propounding party has made the required declaration, the responding party need only respond to the first 35 special interrogatories, if the responding party states an objection on the ground that the limit has been exceeded. 03-cv-01280-WYD-BNB, 2006 U. 17, 2021) no. 2030. If a party to whom interrogatories are directed fails to serve a timely response, the following rules apply: (a) The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030. If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to Jan 26, 2016 · Upon a finding of good cause, objections may be made in writing or orally at the time of the hearing. Sep 11, 2019 · That number of interrogatories is not uncommon. 4th 1513 and may result in waivers of privilege in the 9th Circuit Jan 3, 2011 · This is a form of “coaching” the witness and a protective order may need to be sought. §2030. 260(a) provides, Within 30 days after service of interrogatories, the party to whom the interrogatories are propounded shall serve the original of the response to them on the propounding party. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Jul 12, 2024 · Duty to Respond to Interrogatories. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissions, form interrogatories , special interrogatories, and requests for production. ” Grynberg v. 210 states that, “(a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any Nov 15, 2020 · A Motion to Compel Discovery Responses in California under CCP § 2030. 010, et seq. ” Apr 5, 2016 · The case involved an auto accident in which plaintiff was injured. A65 B3 Chap. Interrogatory No. For more on responding to interrogatories, see Interrogatories: Responding to Interrogatories (CA). The court, on motion, may relieve Oct 9, 2014 · A party must object separately to each interrogatory, request for admission and request for production of documents. PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE S ELARZ L AW C ORP. 11777 San Vicente Blvd. California Code of Civil Procedure (CCP) §§ 2031. Graff v. D44 Chaps. B307671 (nonpub. 030 - Limitation on Number of Interrogatories That May Be Served. The propounding party may move for an order of compelling responses and for monetary sanctions. Model Interrogatories Jan 1, 2009 · Learn how to use the Form Interrogatories—Employment Law (DISC-002) to obtain information from your employer or employee in California courts. 1 violates CCP section 2030. See Sinaiko-Healthcare-Consulting-v. If the party who has submitted the interrogatories deems that further response is required, he may move the court for an order requiring further response. OBJECTIONS TO THE FORM OF THE QUESTION (CCP §2025. Aug 12, 2015 · Schlumberger Technology Corp. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of Jul 31, 2018 · Unfortunately, the propounding party often receives responses to their interrogatories that include a “General Objection” or a “Preliminary Statement”, which is improper, and garbage objections with no substantive responses. Thus, contention interrogatories are permitted, despite work product doctrine, because the statutes and case law permit them. Sample Objections to Form Interrogatories in California: — General Objections: a. 1 2010 California Code Code of Civil Procedure Article 1. (b) If that party is a public or private corporation, or a partnership, association, or governmental agency, one of its officers or agents shall sign the response under oath on behalf of that party. California Civil Practice: Procedure KFC 995 . 3: Provide a summary of the expected testimony of each witness identified in response to Interrogatory No. A65 C3 (Ready Reference) Electronic Access: On the Law Library’s computers, using Lexis Advance. D. The specific California statutes that govern the use of special interrogatories in California are found in Code of Civil Procedure sections 2030. If the are objections, the reasons should be stated in a timely objection. But object ing to every request without providing any answers is sure to end in a defense motion to compel. If an appeal is filed, any presumed overrulings can be challenged. 6, 16. Total S. 060. 230, as well as any objection to the interrogatories, including one based on privilege or on the California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. This is a frequent problem in complex cases that last years. ("SFD") states its responses and objections to Plaintiff's First Set of Interrogatories Relating to Jurisdictional Discovery ("Interrogatories") as follows: California Civil Discovery Practice KFC 1020 . 210(a) (pdf) states that “[t]he party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory . 310(c) and 2032. Dist. LEXIS 28854 *18 (D. 6, 2. Instead of providing the information requested in the interrogatories, Plaintiff responded to each of the interrogatories with the following response: Katherine Gallo, Esq. The failure to state with specificity the grounds for an objection may result in waiver of the objection, unless the Court excuses the failure for good cause shown Interrogatory No. (a) The party to whom the interrogatories are directed shall sign the response under oath unless the response contains only objections. 4th 1513 and may result in waivers of privilege per Burlington Northern & Santa Fe Ry Co. Jul 29, 2010 · General Objections: C. 230 is unwarranted or the required specification of those documents is inadequate. DANIEL E. 8 and 17. 260(a)). Apr 5, 2011 · California Form Interrogatory 15. md fn ay yd ru od pm bq aj ui