Motion-Secondary: NANCY MARIE SCOTT et al VS. AC AND S, INC. et al

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FRANK D. POND (BAR NO. 126191) -
KEVIN D. JAMISON (BAR NO. 222105)
POND NORTH LLP

350 South Grand Avenue, Suite 2850

Los Angeles, CA 90071

Telephone: (2133 617-6170

Facspnile; (213) 623-3594

Attorneys for Defendant CBS Corporation, a
Delaware corporation, f’k/a Viacom Inc.,
successor by merger to CBS Corporation, a
Pennsylvania corporation, f/k/a Westinghouse
Electric Corporation

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

APR 23 2007.
GORDON PARK-LI, Clerk
BY: ALISON AGBAY
Deputy Clerk °

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

NANCY MARIE SCOTT, Individually and as
Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST DOE
through TENTH DOGE, inclusive,

Plaintiffs,
VS.

AC AND S, INC., et al.

Defendants.

Case No: CGC-05-443236

EXHIBIT N TO THE DECLARATION OF
KEVIN D. JAMISON IN SUPPORT OF
DEFENDANT CBS CORPORATION'S
MOTION TO COMPEL FURTHER
RESPONSES TO DISCOVERY, ETC.

_ [SERVED CONCURRENTLY WITH NOTICE OF .

MOTION, MEMORANDUM OF POINTS &
AUTHORITIES, DECLARATION OF KEVIN D,
JAMISON, RULE 3.1020 STATEMENT, AND
PROPCSED ORDER]

Hearing:

Date: May 21, 2007
Time: 10:30am. >
Dept.: 610
Case Filed: July 20,2005
Trial Date: July 16, 2007

EXHIBIT N TO THE DECLARATION OF KEVIN D. JAMISION IN SUPPORT OF CBS CORP.’S MOTION TO
COMPEL FURTHER RESPONSES TO DISCOVERY
4520.1265.243449, 1EXHIBITS

FRANK D. POND (BAR NO. 126191)
KEVIN D. JAMISON (BAR NO. 222105)
TIMOTHY C. PIEPER (BAR NO. 210731)
POND NORTH LLP

350 South Grand Avenue, Suite 2850

Los Angeles, CA 90071

Telephone: (213) 617-6170

Facsimile: (213) 623-3594

Attorneys for Defendant CBS
CORPORATION, a Delaware corporation,
fka Viacom, Inc., successor by merger to
CBS Corporation, a Pennsylvania
corporation, fka Westinghouse Electric
Corporation

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO

NANCY MARIE SCOTT, Individually and as
Successor-in-Interest to DENZIL SCOTT,
‘Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST DOE

Case No: CGC-05-443236

SPECIALLY PREPARED
INTERROGATORIES PROPOUNDED BY
DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET}

through TENTH DOE, inclusive, ONE
Plaintiffs, Judge: TBA
Department: TBA
vs.
Case Filed: July 20, 2005
AC AND §, INC., et al, Trial Date: July 16, 2007
Defendants.

PROPOUNDING PARTY: Defendant, CBS CORPORATION, a Delaware corporation, fka

Viacom, Inc., successor by merger to CBS Corporation, a
Pennsylvania corporation, fka Westinghouse Electric Corporation
RESPONDING PARTY: __ Plaintiff, THOMAS CARY SCOTT

SET NUMBER: ONE

Pursuant to Code Civ. Pro. §§ 2030.010, et seq., defendant CBS CORPORATION, a
Delaware corporation, fka Viacom, Inc., successor by merger to CBS Corporation, a

Pennsylvania corporation, fka Westinghouse Electric Corporation (“WESTINGHOUSE”),
1

‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE

4520,1265,219001.1requests that Plaintiff answer fully in writing and under oath within thirty (30) days of service to
the following specially-prepared Interrogatories.
DEFINITIONS

As used herein, “YOU” and “YOUR” mean and refer to plaintiff THOMAS CARY
ScorT.

As used herein, “WESTINGHOUSE” means and refers to defendant CBS
CORPORATION, a Delaware corporation, fka Viacom, Inc., successor by merger to CBS
Corporation, a Pennsylvania corporation, fka Westinghouse Electric Corporation.

‘As used herein, “DECEDENT” nieans and refers to DENZIL SCOTT.

As used herein, “IDENTIFY” means to provide the full name, current or last known
address, and telephone number, and, if individual is or was an employee of DEFENDANT, all
job titles, of the named individual(s) or entity(ies).

Asused herein, “INVESTIGATIONS” means and refers to all research, interviews,
review, analysis, communications, and other efforts to obtain information.

‘As used in these interrogatories, “STATE ALL FACTS” means to state the brand name
and physical description of the product(s); the type of asbestos fiber; the location at which
DECEDENT was exposed; the dafe of each exposure; how DECEDENT was exposed; the
duration of each exposure; the intensity of each exposure; the frequency of each exposure;
YOUR proximity to the product; the quantity of fiber to which DECEDENT was exposed; and
the events that took place at that location that caused the alleged exposure.

For purposes of these interrogatories, “IDENTIFY EACH PERSON” means to state the
person’s name, last known address, and telephone number.

For purposes of these interrogatories, “IDENTIFY EACH DOCUMENT” means to set
forth the title of the DOCUMENT, if any, the date, the originator or author, the sender, the
recipient(s) and a general description of the content of such document.

For purposes of these interrogatories, DOCUMENT” means a writing, as defined in
Evid. Code § 250, including the originals and all non-identical duplicates, whether different from

the originals by reason of any notation made on such copies or otherwise, and includes, without
2

‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE
4520,1265 2190011limitation, correspondence, memoranda, notes, diaries, statistics, letters, telegrams, telex, telefax,
minutes, contracts, reports, studies, statements, summaries, interoffice and intra-office
communications, notations of any sort of conversations, telephone calls, meetings or other
communications, computer printouts, tape recordings, audiotapes, videotapes, charts, graphs, and
electronic, mechanical or electronic records, compact discs, computer discs, computer tapes,
computer software, electronically stored media, and any other form of stored information.

For purposes of these interrogatories, “SPECIFIED” means to have mandated, in written
form, materials to be applied to, and/or used in conjunction with, any equipment manufactured or
distributed by WESTINGHOUSE.

SPECIALLY-PREPARED INTERROGATORIES
SPECIALLY-PREPARED INTERROGATORY NO. 1:

Please IDENTIFY each individual who provided information for the preparation of
‘YOUR responses to these interrogatories.

(As used herein, “IDENTIFY” means to provide the full name, current or last known
address, and telephone number, and, if individual is or was an employee of DEFENDANT, all
job titles, of the named individual(s) or entity(ies).)

(As used herein, “YOU” and “YOUR” mean and refer to plaintiff THOMAS CARY
SCOTT}

‘SPECIALLY-PREPARED INTERROGATORY NO, 2:

Please describe fully all INVESTIGATIONS undertaken by YOU to obtain the
information sought in these interrogatories.

(As used herein, “INVESTIGATIONS” means and refers to all research, interviews,
review, analysis, communications, and other efforts to obtain information.)
SPECIALLY-PREPARED INTERROGATORY NO. 3:

Do YOU contend that DECEDENT was exposed to asbestos fiber ftom any product

manufactured, sold, supplied, distributed, and/or otherwise put into the stream of commerce by
WESTINGHOUSE?
(As used herein, “DECEDENT” means and refers to DENZIL SCOTT.)
3

‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE
44520,1265,219001.1(As used herein, “WESTINGHOUSE” means and refers to defendant Viacom Inc.,
successor by merger to CBS Corporation, formerly known as Westinghouse Electric
Corporation.)

SPECIALLY-PREPARED INTERROGATORY NO. 4:
For each instance in which YOU contend DECEDENT was exposed to asbestos fiber

from any product manufactured, sold, supplied, distributed, and/or otherwise put into the stream
of commerce by WESTINGHOUSE, STATE ALL FACTS upon which YOU base each
contention.

(As used in these interrogatories, “STATE ALL FACTS” means to state the brand name
and physical description of the product(s); the type of asbestos fiber; the location at which
DECEDENT was exposed; the date of each exposure; how DECEDENT was exposed; the
duration of each exposure; the intensity of each exposure; the frequency of each exposure;
DECEDENT’S proximity to the product; the quantity of fiber to which DECEDENT was
exposed; and the events that took place at-that location that caused the alleged exposure.)
SPECIALLY-PREPARED INTERROGATORY NO. 5:

For each instance in which YOU contend DECEDENT was exposed to asbestos fiber
from any product manufactured, sold, supplied, distributed, and/or otherwise put into the stream.
of commerce by WESTINGHOUSE, IDENTIFY EACH PERSON known to YOU who has
knowledge of the facts upon which YOU base such contention.

(For purposes of these interrogatories, “IDENTIFY EACH PERSON” means to state the
person’s name, last known address, and telephone number.)

SPECIALLY-PREPARED INTERROGATORY NO. 6:

IDENTIFY EACH DOCUMENT supporting YOUR contention that DECEDENT was
exposed to asbestos fiber from any product manufactured, sold, supplied, or distributed by
WESTINGHOUSE.

(For purposes of these interrogatories, “IDENTIFY EACH DOCUMENT” means to set
forth the title of the DOCUMENT, if any, the date, the originator or author, the sender, the

recipient{s) and a general description of the content of such document.)
4

‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE
4520,1265.219001.1Oe a Aw Rw NF

3

ll

(For purposes of these interrogatories, “DOCUMENT” means a writing, as defined in
Evid. Code § 250, including the originals and all non-identical duplicates, whether different from
the originals by reason of any notation made on such copies or otherwise, and includes, without
limitation, correspondence, memoranda, notes, diaries, statistics, letters, telegrams, telex, telefax,
minutes, contracts, reports, studies, statements, summaries, interoffice and intra-office
communications, notations of any sort of conversations, telephone calls, meetings or other
communications, computer printouts, tape recordings, audiotapes, videotapes, charts, graphs, and
electronic, mechanical or electronic records, compact discs, computer discs, computer tapes,
computer software, electronically stored media, and any other form of stored information.)
‘SPECIALLY-PREPARED INTERROGATORY NO. 7:

Do YOU contend that DECEDENT was exposed to asbestos fiber from any product
SPECIFIED by WESTINGHOUSE?

(For purposes of these interrogatories, “SPECIFIED” means to have mandated, in written
form, materials to be applied to, and/or used in conjunction with, any equipment manufactured or
distributed by WESTINGHOUSE.)

SPECIALLY-PREPARED IN’ TERROGATORY NO. 8:

For each instance in which YOU contend DECEDENT was exposed to asbestos fiber
from any product SPECIFIED by WESTINGHOUSE, STATE ALL FACTS upon which YOU
base each contention.

SPECIALLY-PREPARED IN TERROGATORY NO. 9:
For each instance in which YOU contend DECEDENT was exposed to asbestos fiber

from any product SPECIFIED by WESTINGHOUSE, IDENTIFY EACH PERSON known to
YOU who has knowledge of the facts upon which YOU base such contention.
SPECIALLY-PREPARED INTERROGATORY NO. 10:

IDENTIFY EACH DOCUMENT supporting YOUR contention that DECEDENT was
exposed to asbestos fiber from any product SPECIFIED by WESTINGHOUSE.
SPECIALLY-PREPARED INTERROGATORY NO. 11:

Do YOU contend that DECEDENT was exposed to asbestos fiber from any product

SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE

4520,1265.219001.1installed or repaired by WESTINGHOUSE?

| SPECIALLY-PREPARED INFERROGATORY NO.
For each instance in which YOU contend DECEDENT was exposed to asbestos fiber

from any product installed or repaired by WESTINGHOUSE, STATE ALL FACTS upon which

YOU base each contention.
SPECIALLY-PREPARED INTERROGATORY NO. 13:

For each instance in which YOU contend DECEDENT was exposed to asbestos fiber
from any product installed or repaired by WESTINGHOUSE, IDENTIFY EACH PERSON
known to YOU who has knowledge of the facts upon which YOU base such contention.

SPECIALLY-PREPARED INTERROGATORY NO. 14:

IDENTIFY EACH DOCUMENT supporting YOUR contention that DECEDENT was

exposed to asbestos fiber from any product installed or repaired by WESTINGHOUSE.
SPECIALLY-PREPARED INTERROGATORY NO. 15:

Do YOU contend that WESTINGHOUSE negligently caused YOU to be exposed to
asbestos, thereby causing DECEDENT’S disease?
SPECIALLY-PREPARED INTERROGATORY NO. 16:

For each instance in which YOU contend WESTINGHOUSE negligently caused
DECEDENT to be exposed to asbestos, STATE ALL FACTS upon which YOU base such

contention.

SPECIALLY-PREPARED INTERROGATORY NO. 17:

For each instance in which YOU contend WESTINGHOUSE negligently caused
DECEDENT to be exposed to asbestos, IDENTIFY EACH PERSON known to YOU who has
knowledge of the facts upon which YOU base such contention,

SPECIALLY-PREPARED INTERROGATORY NO. 18:
IDENTIFY EACH DOCUMENT supporting YOUR contention that WESTINGHOUSE

negligently caused DECEDENT to be exposed to asbestos.

SPECIALLY-PREPARED INTERROGATORY NO. 19:

Do YOU contend that DECEDENT was exposed to asbestos fiber from products or
6

SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO.
PLAINTIFF THOMAS CARY SCOTT, SET ONE,
4520.1265.219001.1 .activities for which entities other than WESTINGHOUSE are responsible?

SPECIALLY-PREPARED INTERROGATORY Ni
STATE ALL FACTS upon which YOU base YOUR contention that DECEDENT was

exposed to asbestos fiber from products or activities for which entities other than
WESTINGHOUSE are responsible.
SPECIALLY-PREPARED INTERROGATORY NO. 23:

IDENTIFY EACH PERSON known to YOU who has knowledge of the facts related to
DECEDENT’S exposure to asbestos fiber from products or activities for which entities other
than WESTINGHOUSE are responsible.

SPECIALLY-PREPARED INTERROGATORY NO. 22:

IDENTIFY EACH DOCUMENT supporting YOUR contention that DECEDENT was
exposed to asbestos-containing products for which entities other than WESTINGHOUSE are
responsible.

SPECIALLY-PREPARED INTERROGATORY NO. 23:

Do YOU contend that WESTINGHOUSE made any misrepresentation to DECEDENT
regarding any asbestos-containing product?
SPECIALLY-PREPARED INTERROGATORY NO. 24:

STATE ALL FACTS upon which YOU base YOUR contention that WESTINGHOUSE
made any mistepresentation to DECEDENT regarding any asbestos-containing product.
SPECIALLY-PREPARED INTERROGATORY NO. 25:

IDENTIFY EACH PERSON known to YOU who has knowledge regarding facts
supporting YOUR contention that WESTINGHOUSE made any misrepresentation to
DECEDENT regarding any asbestos-containing product.

SPECIALLY-PREPARED INTERROGATORY NO, 26:
IDENTIFY EACH DOCUMENT supporting YOUR contention that WESTINGHOUSE

made any misrepresentation to DECEDENT regarding any asbestos-containing product.

SPECIALLY-PREPARED INTERROGA’ TORY NO. 27:
Do YOU contend that WESTINGHOUSE’ acts, as alleged in YOUR COMPLAINT,
1

SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE
4520.1265.219001.1were done with malice, fraud and/or conscious disregard for the safety of others?

(As-used herein, “COMPLAINT” means and refers to the civil action filed against
WESTINGHOUSE herein, Case No. CGC-05-443236.)
SPECIALLY-PREPARED INTERROGATORY NO. 28:

STATE ALL FACTS supporting YOUR claim that WESTINGHOUSE’s acts, as alleged

in YOUR COMPLAINT, were done with malice, fraud and/or conscious disregard for the safety
of others.
SPECIALLY-PREPARED INTERROGATORY NO. 29:

IDENTIFY EACH PERSON known to YOU who has knowledge regarding facts
supporting YOUR contention that ‘WESTINGHOUSE’s acts, as alleged in YOUR
COMPLAINT, were done with malice, fraud and/or conscious disregard for the safety of others.
SPECIALLY-PREPARED INTERROGATORY NO. 30:

IDENTIFY EACH DOCUMENT supporting YOUR claim that WESTINGHOUSE’s
acts, as alleged in YOUR COMPLAINT, were done with malice, fraud and/or conscious

disregard for the safety of others.
SPECIALLY-PREPARED IN’ TERROGATORY NO. 31:

Describe all facts supporting YOUR claims against WESTINGHOUSE, as alleged in
YOUR COMPLAINT.

SPECIALLY-PREPARED INTERROGATORY NO. 32:

IDENTIFY EACH PERSON known to YOU who has knowledge regarding the facts
supporting YOUR claims against WESTINGHOUSE, as alleged in YOUR COMPLAINT.
SPECIALLY-PREPARED INTERROGATORY NO. 33:

IDENTIFY EACH DOCUMENT supporting YOUR claims against WESTINGHOUSE,

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SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE
4520.1265.219001.1as alleged in YOUR COMPLAINT.

DATED: January 26, 2007 POND NORTH LLP

D, JAMISON
romeys for Defendant CBS
CORPORATION, a Delaware corporation,
fka Viacom, Inc., successor by merger to
CBS Corporation, a Pennsylvania
corporation, tka Westinghouse Electric
Corporation

9
‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE

4520.1265.219001.1Cea aw fF YD

PROOF OF SERVICE
I declare that I am over the age of eighteen (18) and not a party to this action. My

business address is 350 South Grand Avenue, Suite 2850, Los Angeles, CA 90071.

On January 26, 2007, I served the following document(s): SPECIALLY PREPARED
INTERROGATORIES PROPOUNDED BY DEFENDANT CBS ‘CORPORATION TO
PLAINTIFF THOMAS CARY SCOTT, SET ONE on the interested parties in this action by
placing ‘a true and correct copy of such document, enclosed in a sealed envelope, addressed as
follows:

HAROWITZ & TIGERMAN LLP KELLER FISHBACK LLP

430 Sansome Street, 3° Floor 28720 Roadside Drive, Suite 201

San Francisco CA 94111 Agoura Hills CA 91301

Tam readily familiar with the business” practice for collection and processing of
correspondence for mailing with the United States Postal Service. I know that the
correspondence was deposited with the United States Postal Service on the same
day this declaration was executed in the ordinary course of business. I know that
the envelope was sealed and, with postage thereon fully prepaid, placed for
collection and mailing on this date in the United States mail at, Los Angeles,
California

a By overnight Service: I caused the above-referenced document(s) to be deposited
ina box or other facility regularly maintained by the overnight courier, or 1
delivered the above-referenced document(s) to an overnight courier service, for
delivery to the above addressee(s).

a By E-Service: I electronically served the above document(s) via LexisNexis File
& Serve on the recipients designated on the Transaction Receipt located on the
LexisNexis File & Serve website.

a By Personal Service: I caused to be delivered by courier First Legal Support

Services, such envelope by hand to the offices of the above addressee(s).

a By Personal Service: I delivered such envelope by hand to the offices of the
addressee(s).

a By Facsimile Machine: The document was transmitted by facsimile transmission
to the number(s) indicated and was reported as complete and without error.

Executed: January 26, 2007

a (State) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.

a (Gederal) I declare that I am employed in the office of a member of the bar
of this court at direction the service was made.

fe stal
4520A265

‘SPECIALLY PREPARED INTERROGATORIES PROPOUNDED BY DEFENDANT CBS CORPORATION TO.
PLAINTIFF THOMAS CARY SCOTT, SET ONE
4520.1265.219001.1FRANK D. POND (BAR NO. 126191)
KEVIN D. JAMISON (BAR NO, 222105)
TIMOTHY C. PIEPER (BAR NO, 210731)
POND NORTH LLP

350 South Grand Avenue, Suite 2850

Los CA 90071

Telephone: (213) 617-6170

Facsimile:- (213) 623-3594

Attorneys for Defendant CBS
CORPORATION, a Delaware corporation,
fka Viacom, Ine., successor by merger to
CBS Corporation, a Pennsylvania
corporation, fka Westinghouse Electric
Corporation

SUPERIOR COURT OF THE STATE OF CALIFORNIA
¥OR THE COUNTY OF SAN FRANCISCO

NANCY MARIE SCOTT, Individually and as
Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST DOE
through TENTH DOE, inclusive,

Plaintiffs,
vs.
AC AND §, INC., et al.,
Defendants.

Case No: CGC-05-443236

REQUESTS FOR ADMISSION
PROPOUNDED BY DEFENDANT CBS
CORPORATION TO PLAINTIFF
THOMAS CARY SCOTT, SET ONE

Judge: TBA
Department: TBA

Case Filed: July 20, 2005
Trial Date: July 16, 2007

PROPOUNDING PARTY: Defendant CBS CORPORATION, a Delaware corporation, fa
Viacom, Inc., successor by merger to CBS Corporation, a
Pennsylvania corporation, fka Westinghouse Electric Corporation

RESPONDING PARTY:

SET NUMBER: ONE

Plaintiff THOMAS CARY SCOTT

Pursuant to Code Civ. Pro. §§ 2033.010, et seq., YOU are requested to admit within

thirty days after service of this Request for Admissions the truth of each of the following facts.

If YOU deem any of the following requests to be objectionable in whole or in part, state
1

"REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET I

4520.1265.219348.1om 1

with specificity the ground of each such objection. If the request is objectionable in part, admit
or deny as much of the request as is not objectionable.

‘These requests call upon information and knowledge known to YOU and known to
persons acting on YOUR behalf, If YOU have insufficient information to respond to any of
these requests, YOU are required to so state, but YOU are also required to make a reasonable
and good faith inquiry to other persons and organizations to obtain information upon which to
base YOUR response.

RE '§ FOR ADMISSIONS

REQUEST FOR ADMISSIONS NO. 1:
‘Admit that YOU have no evidence that DECEDENT was ever exposed to asbestos-

containing or materials manufactured, sold, supplied, distributed, and/or otherwise put into
commerce by WESTINGHOUSE. (As used herein, “YOU” and “YOUR” means and refers to
plaintiff THOMAS CARY SCOTT; “DECEDENT” means DENZIL SCOTT;
“WESTINGHOUSE” means and refers to defendant CBS CORPORATION, a Delaware
corporation, fka Viacom, Ine., suecessor by merger to CBS Corporation, a Pennsylvania
corporation, fka Westinghouse Electric Corporation.)
REQUEST FOR ADMISSIONS NO. 2:

YOU have no evidence that WESTINGHOUSE caused DECEDENT to be exposed to
asbestos.
REQUEST FOR ADMISSIONS NO. 3:

YOU have no evidence that WESTINGHOUSE is in any way liable for YOUR alleged
injuries.
REQUEST FOR ADMISSIONS NO. 4:

WESTINGHOUSE is not liable to YOU, as alleged in YOUR complaint.

REQUEST FOR ADMISSIONS NO. 5:
WESTINGHOUSE was not negligent toward YOU, as alleged in YOUR complaint.

REQUEST FOR ADMISSIONS. NO. 6;
WESTINGHOUSE is not strictly liable to YOU, as alleged in YOUR complaint.
2

REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1
4520,1265.219348.1REQUEST FOR ADMISSIONS NO. 7:
WESTINGHOUSE made no express warranties to DECEDENT, as alleged in YOUR

complaint.
REQUEST FOR ADMISSIONS NO. 8:

WESTINGHOUSE made ne implied warranties to DECEDENT, as alleged in YOUR
complaint.
REQUEST FOR ADMISSIONS NO. 9:

WESTINGHOUSE is not liable for punitive damages, as alleged in YOUR complaint.
REQUEST FOR ADMISSIONS NO. 10:

No officer, director, or managing agent of WESTINGHOUSE was guilty of or ratified
any acts of malice, fraud, or oppression as that term is defined in Civil Code §3294(c).
REQUEST FOR ADMISSIONS NO. 11:

YOU cannot identify any location where DECEDENT was allegedly exposed to
asbestos-containing products or materials manufactured, sold, supplied, distributed, and/or
otherwise put into commerce by WESTINGHOUSE.

REQUEST FOR ADMISSIONS NO. 12:

YOU cannot identify any dates when DECEDENT was allegedly exposed to asbestos
from products manufactured, sold, or supplied by WESTINGHOUSE.
REQUEST FOR ADMISSIONS NO. 13:

YOU cannot identify any specific product manufactured, sold, or supplied by
WESTINGHOUSE from which YOU claim DECEDENT was subjected to asbestos exposure.
REQUEST FOR ADMISSIONS NO. 14:

YOU have no samples of products or materials YOU contend were manufactured, sold or
supplied by WESTINGHOUSE from which YOU claim DECEDENT was subjected to asbestos
exposure.

REQUEST FOR ADMISSIONS NO. 15:

YOU cannot identify the names of any persons employed by WESTINGHOUSE who

allegedly caused DECEDENT to be exposed to asbestos.

REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1
4520.1265.219348.1a ow ee

uw

REQUEST FOR ADMISSIONS NO. 16:

YOU cannot identify the names of any witnesses with personal knowledge of
DECEDENT?s alleged exposure to asbestos-containing products by WESTINGHOUSE.
REQUEST FOR ADMISSIONS NO. 17:

YOU cannot identify any mistepresentations of material fact relating to asbestos-
containing products made to DECEDENT by WESTINGHOUSE.

REQUEST FOR ADMISSIONS NO. 18:

DECEDENT did not rely on any representations of material fact made to DECEDENT by
WESTINGHOUSE.

REQUEST FOR ADMISSIONS NO. 19:

DECEDENT did not suffer any loss of earnings as a result of her alleged exposure to
asbestos.

REQUEST FOR ADMISSIONS NO. 20:

DECEDENT did not suffer any loss of earning capacity as a result of her alleged
exposure to asbestos.

REQUEST FOR ADMISSION NO. 21:

DECEDENT did not suffer any disability as a result of her alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 22:

YOU or someone acting on YOUR behalf has filed a claim for benefits with the
‘Armstrong World Industries, Inc. Asbestos Personal Injury Settlement Trust arising out of
DECEDENT's alleged exposure to asbestos.

REQUEST FOR ADMISSION NO, 23:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Combustion
Engineering, Inc. atising out of DECEDENT’s alleged exposure to asbestos
REQUEST FOR ADMISSION NO. 24:

‘YOU or someone acting on YOUR behalf has filed a claim for benefits with Pittsburgh
Corning Corporation arising out of DECEDENT’s alleged exposure to asbestos.

Ut

4
REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET]
-4520.1265.219348.1Cm a aw he ON

3

REQUEST FOR ADM! ISSION NO. 25:
YOU or someone acting on YOUR behalf has filed a claim for benefits with Kaiser

‘Aluminum Corporation arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 26:

{YOU or someone acting on YOUR behalf has filed a claim for benefits with North
“American Refractories arising out of DECEDENT’s alleged exposure to asbestos.

REQUEST FOR ADMISSION NO. 27:

YOU ot someone acting on YOUR behalf has filed a claim for benefits with the Celotex
‘Asbestos Settlement Trust arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 28:

‘YOU or someone acting on YOUR behalf has filed a claim for benefits with Eagle
Pitcher Industries arising out of DECEDENT’s alleged exposure to asbestos.

REQUEST FOR ADMISSION NO. 29:

‘YOU or someone acting on YOUR behalf has filed a claim for benefits with UNR
Industries arising out of DECEDENT’s alleged exposure to asbestos.

REQUEST FOR ADMISSION NO. 30:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Forty-Eight
Insulations arising out of DECEDENT’s alleged exposure to asbestos.

REQUEST FOR ADMISSION NO. 31:

YOU or someone acting on YOUR behalf has filed a claim for benefits with H. K. Porter
arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 32:

YOU or someone acting on YOUR behalf has filéd a claim for benefits with Johns-
Manville arising out of DECEDENT’s alleged exposure to asbestos.

REQUEST FOR ADMISSION NO. 33:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Keene
Corporation arising out of DECEDENT’s alleged exposure to asbestos.

il
5

REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1

4520.1265.219348.1REQUEST FOR ADMISSION NO. 34:
YOU or someone acting on YOUR behalf has filed a claim for benefits with Owens

Corning Corporation arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 35:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Standard *
Tnsulations arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 36:

YOU or someone acting on YOUR behalf has filed a claim for benefits with W. R. Grace
arising out of DECEDENT’s alleged exposure to asbestos:
REQUEST FOR ADMISSION NO. 37:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Harbison-
Walker arising out of DECEDENT’s alleged exposure to asbestos.

JUEST FOR ADMISSION NO. 38:

YOU or someone acting on YOUR behalf has filed a claim for benefits with AP Green

Industries arising out of DECEDENT’s alleged exposure to asbestos.
JUEST FOR ADMISSION NO. 39:

YOU or someone acting on YOUR behalf has filed a claim for benefits with J.T. Thorpe
arising out of DECEDENT’s alleged exposure to asbestos.
RE FOR ADMISSION NO. 40;

YOU or someone acting on YOUR behalf has filed a claim for benefits with MacArthur
Company arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 41:

‘YOU or someone acting on YOUR behalf has filed a claim for benefits with MH.
Detrick arising out of DECEDENT’s alleged exposure to asbestos.
REQUEST FOR ADMISSION NO. 42:

YOU or someone acting on YOUR behalf has filed a claim for benefits with Shook &
Fletcher Insulation arising out of DECEDENT’s alleged exposure to asbestos.
Hit

6

REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1

4520.1265 219348.1REQUEST FOR ADMISSION NO. 43:
YOU or someone acting on YOUR beha!f has filed a claim for benefits with asbestos

manufacturers not otherwise specified herein arising out of DECEDENT’s alleged exposure to
asbestos.

REQUEST FOR ADMISSION NO. 44:
YOU or someone acting on YOUR behaif has filed a claim for benefits with asbestos

trusts not otherwise specified herein arising out of DECEDENT's alleged exposure to asbestos.

DATED: January 26, 2007 POND Tp

By:

D. JAMISON,
wneys for Defendant CBS
CORPORATION, a Delaware comportin,

iacom, Inc., successor by merger to
CBS Corporation, a Pennsylvania
corporation, fka Westinghouse Electric
Corporation

1
REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1

4520.1265.219348.1PROOF OF SERVICE
declare that I am over the age of eighteen (18) and not a party to this action. My

business address is 350 South Grand Avenue, Suite 2850, Los Angeles, CA 90071.
On January 26, 2007, I served the following document(s): REQUESTS FOR

ADMISSION PROPOUNDED BY DEFENDANT CBS CORPORATION TO PLAINTIFF

THOMAS CARY SCOTT, SET ONE on the interested parties in this action by placing a true

and correct copy of'such document, enclosed in a sealed envelope, addressed as follows:

HAROWITZ & TIGERMAN LLP KELLER FISHBACK LLP

450 Sansome Street, 3° Floor 28720 Roadside, Suite 201

San Francisco CA 94111 ‘Agoura Hills CA 91301

a Iam readily familiar with the business’ practice for collection and processing of
correspondence for mailing with the United States Postal Service. I know that the
corres; was deposited with the United States Postal Service on the same
day this declaration was executed in the ordinary course of business. I know that
the envelope was sealed and, with postage thereon fully prepaid, placed for
collection and mailing on this date in the United States mail at, Los Angeles,
California

a By overnight Service: I caused the above-referenced document(s) to be deposited
in a box or other facility regularly maintained by the overnight courier, or I
delivered the above-referenced document(s) to an overnight courier service, for
delivery to the above addressee(s).

Q By E-Service: I electronically served the above document(s) via LexisNexis File
& Serve on the recipients designated on the Transaction Receipt located on the
LexisNexis File & Serve website.

a By Personal Service: I caused to be delivered by courier First Legal Support
Services, such envelope by hand to the offices of the above addressee(s).

a By Personal Service: I delivered such envelope by hand to the offices of the
addressee(s).

Qo By Facsimile Machine: The document was transmitted by facsimile transmission
to the number(s) indicated and was reported as complete and without error.

Executed: January 26, 2007

B (State) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.

o (Federal) - I declare that I am employed in the office of a member of the bar
of this court at wi nection the service was made.

iste
4529-1265

REQUESTS FOR ADMISSION PROPOUNDED BY DEF. CBS CORPORATION TO PLTF. THOMAS CARY
SCOTT, SET 1

4520,1265.219348.1Ce a Aw ew

FRANK D. POND (BAR NO. 126191)
KEVIN D. JAMISON (BAR NO. 222105)
TIMOTHY C. PIEPER (BAR NO. 210731)
POND NORTH LLP

350 South Grand Avenue, Suite 2850

Los Angeles, CA 90071

Telephone: (213) 617-6170
Facsimile: (213) 623-3594
Attomeys for Defendant CBS:

CORPORATION, a Delaware corporation,
fica Viacom, Inc., successor by merger to
CBS Corporation, a Pennsylvania
corporation, fka Westinghouse Electric
Corporation

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO.

NANCY MARIE SCOTT, Individually and as
Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST DOE
through TENTH DOE, inclusive,

Plaintiffs,
vs.
AC ANDS, INC., et al.,
Defendants.

Case No: CGC-05-443236

DECLARATION IN SUPPORT OF
ADDITIONAL DISCOVERY RE
REQUESTS FOR ADMISSION
PROPOUNDED BY DEFENDANT CBS
CORPORATION TO PLAINTIFF
THOMAS CARY SCOTT, SET ONE

Judge: TBA
Department: TBA

Case Filed:
Trial Date:

July 20, 2005
July 16, 2007

1, KEVIN D, JAMISON, declare as follows:

1. Lam an attorney at law licensed by and in good standing with the State of

California. T am an associate with the law firm of Pond North LLP, the attorneys of record for

defendant CBS CORPORATION, a Delaware corporation, fka Viacom, Inc., successor by

merger to CBS Corporation, a Pennsylvania corporation,

fka Westinghouse Electric Corporation

(“Westinghouse.”) I have personal knowledge of the facts set forth herein, and if called as a

witness, I would be able to competently testify to those facts.
2. Westinghouse is propounding to plaintiff THOMAS CARY SCOTT a set of
I

DECL. IN SUPPORT OF ADD'L DISC. RE REQ. FOR ADMISSION PRO'D BY DEF. CBS CORP. TO PLTF.
THOMAS CARY SCOTT

4520.1265.220093.1Requests for Admission, designated as “Set One”, which are being served concurrently with this
Declaration.

3. This set of Requests for Admission will cause the total number of requests
[propounded to plaintiff to exceed the number of requests permitted by Section 203.030 of the

Code of Civil Procedure.

4, Westinghouse has not previously propounded any Requests for Admission to
plaintiff.

5. This set of Requests for Admission contains a total of 44 requests.

6. Lam familiar with the issues and the previous discovery conducted by all the
parties in this case,

7. Thave personally examined each of the requests in this set of requests for
admission.

8. This number of requests for admission is warranted under Section 2033.040 of the
Code of Civil Procedure because it is essential to our client’s defense to determine whether
plaintiff filed claims for benefits with any asbestos manufacturers or asbestos settlement trust
funds.

9. None of the requests in this set of requests is being propounded for any improper
purpose, such as to harass plaintiff, or the attomey for plaintiff, or to cause unnecessary delay or
needless increase in the cost of litigation.

I declare under the penalty of perjury that the for.
Declaration was executed this 26" day of Jam

ving is true and correct, and that this

Los nia.

ANN ‘D. JAMISON

2
DECL. IN SUPPORT OF ADD'L DISC. RE REQ. FOR ADMISSION PRO'D BY DEF. CBS CORP. TO PLTF.
THOMAS CARY SCOTT

4520 1965 220003 1PROOF OF SERVICE

I declare that I am over the age of eighteen (18) and not a party to this action. My
business address is 350 South Grand Avenue, Suite 2850, Los Angeles, CA 90071.

IECLARATION IN

On January 26, 2007, I served the following document(s
SUPPORT OF ADDITIONAL DISCOVERY RE REQUEST:
PROPOUNDED BY DEFENDANT CBS CORPORATION TO PLAINTIFF THOMAS
‘CARY SCOTT, SET ONE on the interested parties in this action by placing a true and correct
copy of such document, enclosed in a sealed envelope, addressed as follows:

HAROWIFZ & TIGERMAN, LLP KELLER FISHBACK LLP

450 Sansome Street, 3 Floor 28726 Roadside Drive, Suite 261

San Francisco CA 94111 Agoura Hills CA 91301

& am readily familiar with the business’ practice for collection and processing of

correspondence for mailing with the United States Postal Service. 1 know that the
correspondence was deposited with the United States Postal Service on the same
day this declaration was executed in the ordinary course of business. I know that
the envelope was sealed and, with postage thereon fully prepaid, placed for
collection and mailing on this date in the United States mail at, Los Angeles,
California

a By overnight Service: I caused the above-referenced document(s) to be deposited
in a box or other facility regularly maintained by the overnight courier, or I

delivered the above-referenced document(s) to an overnight courier service, for
delivery to the above addressee(s).

Oo By E-Service: I electronically served the above document(s) via LexisNexis File
& Serve on the recipients designated on the Transaction Receipt located on the
LexisNexis File & Serve website.

a By Personal Service: I caused to be delivered by courier First Legal Support
Services, such envelope by hand to the offices of the above addressee(s).

a By Personal Service: I delivered such envelope by hand to the offices of the
addressee(s).

a By Facsimile Machine: The document was transmitted by facsimile transmission
to the number(s) indicated and was reported as complete and without error.

Executed: January 26,2007
(State) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.

a (Federal) 1 declare that I am employed in the office of a member of the bar
of this court at direction the service was made.

fora Cry:
520-124

DECL. IN SUPPORT OF ADDL DISC. RE REQ. FOR ADMISSION PROD BY DEF. CBS CORP. TO PLTF.
THOMAS CARY SCOTT

(8590 1965 990003 1“ATTORNEY OR PARTY WITHOUT ATTORNEY (No, tate frau and aces
Frank D. Pond (SBN 12618
[Timothy C. Pieper (SBN 210731)
POND NORTH LLP

360 S, Grand Avenue, Suite 2850
Los Angeles, California 90071-3438

; Kevin D. Jamison (SBN222105) axwo.(optonen: (213) 623-3594

arornevror psn: Defendant CBS CORPORATION, fka Viacom, Inc., etc.

Jeuerroneno: (213) 617-6170

[Ee ADDRESS (Option:

UNLIMITED JURISDICTION
BRANCH, IF ANY:

"SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO

| SHORT TITLE OF CASE:
SCOTT v. AC AND S, INC..,et al.

FORM INTERROGATORIES:

‘Answering Party: Plaintiff Thomas Cary Scott
Set No.: One

‘Asking Party: Defendant CBS CORPORATION, fka Viacom, inc, 6.

‘CASE NUMBER

CGC-05-443236

Sec. 1. Instructions to All Parties

{@) interrogatories are written questions prepared by a party
to an action that are sent to any other party in the action to be
answered under oath. The interrogatories below are form
interrogatories approved for use in civil cases.

(©). For time limitations, requirements for service on other
parties, and other details, see Code of Civil Procedure section
2030 and the cases construing it.

(©) These form interrogatories do not change existing law
felating to interrogatories nor do they affect en answering
party's right to assert any privilege or make any objection,

‘See, 2. Instructions to the Asking Party

(a) These interrogatories are designed for optional use by
patties in unlimited civil cases where the amount demanded
exceeds $25,000, Separate ir ries, Form.
Interrogatories—Economic Litigation (form F-128), which have
no subparts, are designed for use in limited civil cases where
the amount demanded is $25,000 or less; however, those
interrogatories may also be used in unlimited civil cases.

(b) Check the box next to each interrogatory that you want
the answering party to answer. Use care in choosing those
interrogatories that are applicable to the-case.

(© You may insert your own definition of INCIDENT in
Section 4, but only where the action arises from a course of
Conduct of a series of events occurring over a period of time.
{@)_ The interrogatories in section 16.0. Defendant's
Contentions—Persorial Injury, should not be used until the
defendant has had a reasonabte opportunity to conduct an
investigation or discovery of plaintif’'s injuries and damages.

{e) Additional interrogatories may be attached.

Sec. 3. Instructions to the Answering Party

(a) An answer or other appropriate response must be
given to each interrogatory checked by the eeking party.

{b). Asa general rule, within 30 days after you are served
with these interrogatories, you must serve your responses on
the asking party and serve copies of your responses on all
other parties to the action who have appeared. See Code of
Civil Procedure section 2030 for details.

(©) Each answer must be as complete and straightforward
228 the information reasonably available to you, including the
information possessed by your attomeys or agents, permits. If
‘an interrogatory cannot be answered completely, answer it to
the extent possible.

(6) Ifyou do not have enough personal knowledge to fully
answer an intetrogatory, say s0, but make a reasonable and
{900d faith effort to get the information by asking other persons
or organizations, unless the information is equally available to
the asking party.

(©) Whenever an interrogatory may be answered by
referring to a document, the document may be attached as an
‘exhibit to the response and referred to in the response. If the
document has more than one page, refer to the page and
section where the answer to the interrogatory can be found.

() Whenever an address and telephone number for the
‘Same person are requested in more than one interrogatory,
you are required to furnish them in answering only the first
interrogatory asking for that information.

(g)_ if you are asserting a privilege or making an objection to
an interrogatory, you must specifically assert the privilege or
state the objection in your written response.

(h) Your answers to these interrogatories must be verified,
dated, and signed. You may wish to use the following form at
the end of your answers:

1 declare under penalty of perjury under the laws of the
State of Cafforla that the foregoing answers are true and
conect

(DATE) (SIGNATURE)

‘Sec. 4. Definitions
Words in BOLDFACE CAPITALS in these interrogatories
are defined 2¢ follows:
(2) (Check one ofthe following):
BY (1) INCIDENT includes the circumstances and
‘events surrounding the alleged accident, injury. or
‘other occurrence or breach of contract giving rise to
this action or proceeding.

Paes

Form AeprovedierOpinal Use
“dela Coes of Galfer.
‘42 eva 1,205)

FORM INTERROGATORIES

‘Cae of  Proama,G208, 208

ee1 @ INCIDENT means finsert your definition here or
on a separate, attached sheet labeled “Sec.
MaN2)):

{b) YOU OR ANYONE ACTING ON YOUR BEHALF
includes you, your agents, your employees, your insurance
‘companies, their agents, their employees, your attorneys, your
‘accountants, your investigators, and anyone else acting on
‘your behalf.

(©) PERSON includes a natural person, firm, association,
cerganization, partnership, business, trust, limited liability
company, corporation, or pubic entity.

(a) DOCUMENT means a writing, as defined in Evidence
Code section 250, and includes the original or a copy of
handwriting, typewriting, printing, photostats, photographs,
electronically stored information, and every other means of
recording upon any tangible thing and form of communicating
or representation, including letters, words, pictures, sounds, or
symbols, of combinations of them,

(@) HEALTH CARE PROVIDER includes any PERSON
Teferred to in Cade of Civil Procedure section 687.7(e)(3).

() ADDRESS means the street address, including the city,
state, and zip code.

Sec. . interrogatories

‘The following interrogatories have been approved by the
Judicial Council under Code of Civil Procedure section 2033.5:

CONTENTS

41.0 Identity of Persons Answering These interrogatories
2.0 General Background Information-—Individual
3.0 General Background Information—Business Entity
4.0 Insurance
5.0 [Reserved
6.0 Physical, Mental, or Emotional Injuries
7.0 Property Damage
8.0 Loss of Income or Earning Capacity
9.0 Other Damages
10.0 Medical History
14.0 Other Claims and Previous Claims
12.0 Investigation—General
18.0 Investigation—Surveillance
44.0 Statutory or Regulatory Violations :
45.0 Denials and Special or Affirmative Defenses
48.0 Defendant's Contentions Persoral injury
17.0 Responses to Request for Admissions
18.0 [Reserved]
18.0 (Ressrved}
20.0 How the Incident Occurred—Motar Vehicle
25.0 [Reserved]
30.0 [Reserved]
‘40.0 (Reserved)
50.0 Contract
60.0 [Reserved
70.0 Unlawful Detainer [See separate form Fl-126]
101.0 Economic Litigation {See separate form Fi-129]
200.0 Employment Law [See separate form Fi-130]
Family Law [See separate form 1292.10]

1.0 Identity of Persons Answering These interrogatories

BW 1.1 State the name, ADDRESS, telephone number, and
relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. (Do not identify anyone who simply typed or
reproduced the responses.)

2.0 General Background Information—individual

D 21 State:
fa) your name;
(©) every name you have used in the past; and
(©) the dates you used each name.

C 22 State the date and place of your birth.

C1 2:3 At the time of the INCIDENT, did you have a drivers.
license? If so state:
{@) the state or other issuing entity;
(©) the license number and type;
(©) the date of issuance; and
(@) all restrictions.

1X 24 Atthe time of the INCIDENT, did you have any other
permit or license for the operation of a motor vehicle? if so,
state:
(@) the state or other issuing entity;
(©) the license number and type:
(©) the date of issuance; and
() all restrictions.

O 25 State:
(a) your present residence ADDRESS;
(b) your residence ADDRESSES for the past five years; and
(©) the dates you lived at each ADDRESS.

O 26 state:
{@) the name, ADDRESS, and telephone number of your
present employer or place of self-employment; and
{b) the name, ADDRESS, dates of employment, job title,
and nature of work for each employer or self-
‘employment you have had from five years before the
INCIDENT until today.

D 27 State:

{a) the name and ADDRESS of each school or other
academic or vocational institution you have attended,
beginning with high school;

(©) the dates you attended;

(©) the highest grade level you have completed; and

{d) the degrees received.

LY 2.8 Have you ever been convicted of a felony? if so, for
‘each conviction state:
{) the city and state where you were convicted;
{©) the date of conviction;
(©) the offense; and
{d), the court and case number.

BI 29 Can you speak English with ease? If not, what
language and dialect do you normally use?

B® 2.10 can you read and write English with ease? If not, what
language and dialect do you normally use?

F120 fer hay 7 2098)

FORM INTERROGATORIES(1 2.14 Atthe time of the INCIDENT were you acting as an.
agent or employee for any PERSON? If so, state:
(@) the name, ADDRESS, and telephone number of that
PERSON: and
(b) a description of your duties.

1] 2.12 At the time of the INCIDENT did you or any other
person have any physical, emotional, or mental disability or
‘condition that may have contributed to the occurrence of the
INCIDENT? i 50, for each person state:

(@) the name, ADDRESS, and telephone number,

(6) the nature of the disability or condition: and

(© the manner in which the disability or
conitibuted to the occurrence of the INCIDENT.

2.13 Within 24 hours before the INCIDENT did you or any
person involved in the INCIDENT use or take any of the

. following substances: alcoholic beverage, marijuana, or
other drug or medication of any kind {prescription or not)? if

0, for each person state:

(@) the name, ADDRESS, and telephone number;

(b) the nature or description of each substance;

(©) the quantity of each substance used or taken;

(@) the cate and time of day when each substance was used
or taken;

(©) the ADDRESS where each substance was used or
taken;

(the name, ADDRESS, and telephone number. of each
person wio was present when each substance was used
or taken; and

(@) the name, ADDRESS, and telephone number of any
HEALTH GARE PROVIDER who prescribed or fumished
the substance and the condition -for which it was
prescribed or furnished.

3.0 General Background information—Business Entity
3.1 Are you a corporation? If so, state:

(@) the name stated in the current articles of incorporation;

() all other names used by the corporation during the past
10 years and the dates each was used;

(©) the date and place of incorporation;

(@) the ADDRESS of the principal place of business; and

(@) whether you are qualified to do business in California.

condition

1 32 Are youa partnership? If so, state:

{@) the current partnership name;

() all other names used by the partnership during the past
10 years and the dates each was used:

(©) whether you are a limited partnership and, if so, under
the kaws of what jurisdiction;

(@) the name and ADDRESS of each general partner, and

{@) the ADDRESS of the principal place of business.

1 3.3 Are you a limited liabitty company? If s