Q: credible information about identities - response to interrogatory.

A: To answer this question, let's break down the key elements and consider the legal requirements for responding to interrogatories in California:

1. Interrogatory definition: If the plaintiff did not provide a specific definition of "identity characteristics" in their interrogatory, this creates some ambiguity.

2. Duty to respond: In California, a party has a duty to respond to interrogatories to the best of their ability, even if the question is somewhat vague or broad.

3. Good faith requirement: Responses must be made in good faith, providing information that is reasonably available to the responding party.

4. Scope of response: Given the lack of specificity, the defendant should provide information that would reasonably be considered as identifying characteristics. This might include:

- Names

- Addresses

- Phone numbers

- Email addresses

- Physical descriptions

- Job titles or roles

- Any other information that could help identify the individuals in question

5. Objections: While objecting to the interrogatory without providing any information is an option, it's generally not recommended unless the interrogatory is truly improper or impossible to answer. In this case, a better approach might be:

a. Provide a response with the information you believe is relevant to identities.

b. Include an objection stating that the term "identity characteristics" is vague and overly broad.

c. Clarify in your response what information you're providing and why you believe it meets the request.

6. Meet and confer: If there's genuine confusion about what the plaintiff is seeking, the defendant's attorney should consider reaching out to opposing counsel to clarify the scope of the interrogatory.

7. Supplemental responses: Remember that in California, parties have an ongoing duty to supplement their responses if new information becomes available.

In conclusion, unless there's a valid reason for a full objection, the defendant should provide credible information that reasonably relates to identifying individuals, while potentially objecting to the vagueness of the term "identity characteristics" and explaining the scope of the information provided.

If you need more specific advice about how to respond to this particular interrogatory, I recommend consulting with a California-licensed attorney who can review the full context of your case and the specific wording of the interrogatory.