Model interrogatories for a defendant to use in a securities fraud lawsuit. This Standard Document contains integrated drafting notes with important explanations and tips for drafting the caption, introduction, definitions, instructions, and specific interrogatories defendants can use in cases brought by private plaintiffs alleging material misstatements or omissions in violation of Section 10(b) of the Securities Exchange Act of 1934 and Securities and Exchange Commission Rule 10b-5. It also contains a blank verification form, a signature block, and proof of service.