CARLEY, Chief Judge.
Appellee-plaintiffs brought suit against appellant-defendant, seeking to recover for unpaid insurance premiums. Appellant answered, denying the material allegations of appellees' complaint. Thereafter, appellant was served with a set of interrogatories and appellant for admission. One of appellees' interrogatories asked appellant to state "the factual basis for each and every defense you have to this presently pending action." In his sworn response...
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