Exhibit,Appendix: NANCY MARIE SCOTT et al VS. AC AND S, INC. et al

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                                RAYMOND 1.. GILL (SBN 153529)
JOHNNY D. KNADLER (SBN 220942)
KIRKPATRICK & LOCKHART PRESTON
GATES ELLIS LLP

55 Second Street, Suite 1700

San Francisco, CA 94105

Telephone: (415) 882-8200

Facsimile: (415) 882-8220

Attomeys for Defendant
SQUARE D COMPANY

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

MAR 28 2007
GORDON PARK-LI, Clerk
BY: EDNALEEN JAVIER-LACSON
Deputy Cler

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

NANCY MARIE SCOTT, ct al.,
Plaintiffs,
VS,

AC AND §, INC., et al.,

Defendants.

ASBESTOS-RELATED CASE
Case No. 443236

EXHIBITS C THROUGH E TO
DECLARATION OF JOHNNY D.
KNADLER IN SUPPORT OF DEFENDANT
SQUARE D COMPANY’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE

ALTERNATIVE, SUMMARY
ADJUDICATION

Date: June 15, 2007

Time: 9:30 a.m.

Dept: 302

Judge: Hon. Patrick Mahoncy

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

EXITBITS C THROUGH E TO DECLARATION OF JOHNNY D. KNADLER IN SUPPORT OF DEFENDANT

SQUARE D COMPANY'S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATIONEXHIBIT CFiat

"ATTORNEY OR PARTY WITHOUT ATTORNEY Nama, SelB nonbar and eos)

ymond L. Gill (SBN 153529)
Sehnny D. Knadler (SBN 220942)

Four Embarcadero Center, 10th Ploor
San Francisco, CA 94111

Taewoneno: (415) 249-1000

FAKHO.(Opteoa’ (415) 249-1001

[EMAL ADORESS (Opto

ATTORNEYFOR Nang: SQuare D_ Company

KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP

‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco

‘SHORT TITLE OF CASE: Nancy Marie Scott, et al. vs. AC and 8, Inc., et al.

SetNo.: One (1)

FORM INTERROGATORIES—GENERAL
Asking Party: Defendant Square D Company

Answering Party: Plaintiff Nancy Marie Scott

CASE RINGER
cGc-05-443236

‘Sec. 1. Instructions to All Partios
{a)_ interrogatories are written questions prepared by a party
‘0 an action that are sent to any other party in the acon to be
answered under oath. The interrogatories below are form
interrogatories approved for use in civil cases.

(©) _ For time limitations, requirements tor service on other
parties, and other details, see Code of Civil Procedure sections
'2030.010-2030.410 and the cases construing those sections.

(c) These form interrogatories do not change existing taw
relating to interragatories nor do they affect an answering
anys right to assert any privilege or make any objection.
‘Sec. 2, Instructions to the Asking Party

(2). Those interrogatories are designed for optional use by
parties in unlimited civil cases where the amount demended
exceeds $25,000. Separate interrogatories, Form
Interogatorles—~Economic Litigation (form F1-128), 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 or a series of events occurring over a period of time.
(d)_ The interrogatories in section 16.0, Defendant's
Contentions—Personal Injury, should not be used until the
defendant has had a reasonable 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 asking party.

(0) 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
Civit Procedure section 2030.260-2030.270 for details.

(©) Each answer must be as complete and straightforward
2s the information reasonably available to you, including the
Information possessed by your aftomeys or agents, permis,
Ian interrogatory cannot be answered completely, answer it
to the extent possible,
(6) _ Ifyou do not have enough personal knowledge to fully
answer an interrogatory, say so, but make a reasonable and
‘good feith effort to get the information by asking other persons,
‘or organizations, unless the information is equally available to
the asking party.
(e)__ 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. ifthe
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
interrogetory asking for that inforration.
(@) _ Ifyou are asserting a privitege or making an objection to
an interogatory, 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:

| dactare under penalty of perjury under the laws of the
‘State of California that the foregoing answers are true and
correct.

DATES (SIGNATURE
Sec. 4, Definitions

Words in BOLDFACE CAPITALS in these interrogatories
are defined as follows:
(2) (Check one of the following):
[1 (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. Page tot

Fumo : Onforel Usa
‘hell Gena of Clara
a0 elon 20D]

FORM INTERROGATORIES—GENERAL

Code Cit Preeti,
sg 20m or0.2080410, 2008710@) INCIDENT means (insert your definition here or
on a separate, attached stieet labeled "Sec.
Ha}(2N:

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

{©} PERSON includes 2 natural person, firm, association,
organization, partnership, business, trust, limited liability
company, corporation, or public entity.

(@) 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, or combinations of them.

(e) HEALTH CARE PROVIDER includes any PERSON
referred to in Code of Civil Procedure saction 667.7(@)(3)..

(f) ADDRESS means the street address, including the city,
state, and zip code.
Sec. 5. interrogatories

‘The following interrogatories have been approved by the
Judielal Couneit under Code of CMI Procedure section 2033.710:

CONTENTS:

1.0. Identity of Persons Answering These Intergatories
2.0 General Background information—individual

3.0 General Background Information—Business Entity
Insurance:

[Reserved]

Physical, Mental, or Emotional Injuries

Property Damage

Loss of Income or Eaming Capacity

‘Other Damages

Medical History

‘Other Claims and Previous Claims

Investigation — General

Investigation — Surveillance

Statutory or Regulatory Violations

Denials and Special or Affirmative Defenses
Defendant's Contentions Personal Injury
Responses to Request for Admissions
[Reserved]

[Reserved]

How the Incident Occurred—Motor Vehicle

(Reserved)

Unlawful Dotainer See separate form Fl-128]
Economic Litigation (See separate form Fi-129]
Employment Law {See separate form FI-130}
Family Law [See separate form 1292.10]

F420
1.0 Identity of Persons Answering These interrogatories

CJ 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. (D0 not identity anyone who simply typed
Cr reproduced the responses.)

2.0_ General Background Information—individual

C7 2.4 state:

(a) your name;
(0) every name you have used in the past; and
(c) the dates you used each name,

([) 22 State the date and place of your birth.

(J 2:3 At the time of the INCIDENT, did you have a driver's
license? if so, state:
{a} the state or other issuing entity;
(0) the license number and type;
(c) the date of issuance; and
(@) ali restrictions.

(—) 24 At the time of the INCIDENT, did you have any other
Permit or license for the operation of a motor vehicle? If
80, state:
(2) the state or other issuing entity;
(0) the license number and type:
{¢) the date of issuance; and
(@) ail restrictions

C2 25 state:
(@) your present residence ADDRESS;
(0) your residence ADDRESSES for the past five years;
and
(@) the dates you lived at each ADDRESS.

1 26 state:
(@) the name, ADDRESS, and telephone number of your
present emplayer or place of self-employment; and
(0) the name, ADDRESS, dates of employment, job tite,
‘and nature of work for sch employer ar setf-
‘employment you have had from five years before the
INCIDENT unl today.

C3 27 State:

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

(0) the dates you attended;

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

(a) the degrees received.

[) 2.8 Have you ever been convicted of a felony? If so, for
‘each conviction state:
(a) the city and state whore you were convicted;
(b) the date of conviction;
(¢) the offense; and
(@) the court and case number.

([[) 28 Can you speak English with ease? If not, what
language and dialect do you normally use?

[2:10 Can you read and write English with ease? If not,
‘what language and dialect do you normally use?

aime Rav dary 1 OT

FORM INTERROGATORIES—GENERAL

Pomona(2) 2.11 At the time of the INCIDENT were you acting as an
agent or employee for any PERSON? If so, state:

@
eo

the name, ADDRESS, and telephone number of that
PERSON; and
{a description of your duties.

[7 2:12 At the time of the INCIDENT did you or any other
person have any physical, emotional, or mentat disability or
condition that may have contributed to the occurrence of the.
INCIDENT? Ifo, for each person state:

@)
(e)
©

the name, ADDRESS, and telephone number;
the nature of the disability or condition; and

the manner in which the disability or condition
contributed 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:

f@)
oe}
©
@
e

@

@

‘the name, ADDRESS, and telephone number;

the nature or description of each substance;

the quantity of each substance used or taken;

the date 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 who was present when each substance was used
or taken; and

the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who prescribed or furnished
the substance and the condition for which It was
prescribed or furnished.

3.0 General Background Information — Business Entity

‘Are you a corporation? If 0, state:
the name stated in the current articles of incorporation;
all other names used by the corporation during the past
40 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.

‘Are you a 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 faws of what jurisdiction;

the name and ADDRESS of each general partner; and
the ADDRESS of the principal place of business.

‘Are you a limited liability company? If so, state:
the name stated in the current articles of organization;
all other names used by the company during the past 10
years and the date each was used;

the date and place of filing of the articles of organization;
the ADDRESS of the principal place of business; and
whether you are qualified to do business in California.

F420
() 3.4 Are you a joint venture? If so, state:
(@) the current joint venture name;
(0) aff other names used by the joint venture during the past
10 years and the dates each was used:
(©) the name and ADDRESS of each joint venturer, and
(@) the ADDRESS of the principal place of business.

(J 3.5 Are you an unincorporated association?
Ifso, state:
(a) the current unincorporated association name;
(b) all other names used by the unincorporated association
during the past 10 years and the dates each was used;
and

(¢) the ADDRESS of the principal place of business.

[5 3.6 Have you done business under a fictitious name during
the past 10 years? If so, for each fictitious name state:
(@) the name;
(0) the dates each was used;
(©) the state and county of each fictitious name
(d) the ADDRESS of the principal place of business.

js and

[J 3,7 Within the past five years has any public entity regis-
tered or lcensed your business? If so, for each license or
registration:

{a) identity the license or registration;
(0) state the name of the public entity; and
(6) stata the dates of issuance and expiration.

4.0. Insurance

{J 4.1 At the time of the INCIDENT, was there in effect any
policy of insurance through which you were or might be
insured in any manner (for example, primary, pro-rata, or

liability coverage or medical expense coverage) for

the damages, claims, or actions that have arisen out of the

INCIDENT? Ifo, for each policy state:

{) the kind of coverage;

(0) the name and ADDRESS of the insurance company:

(©) the name, ADDRESS, and telephone number of each
named insured:

{@) the policy number;

{e) the limits of coverage for each type of coverage con-
tained in the policy;

(f) whether any reservation of rights or controversy or
coverage dispute exists between you and the insurance
company; and

(9) the name, ADDRESS, and telephone number of the
‘custodian of the policy.

(42 Ave you self-insured under any statute for the damages,
claims, or actions that have arisen out of the INCIDENT? If
0, specify the statute.

5.0 [Reserved]

6.0 Physical, Mental, or Emotional Injuries

[£1 611 De you attribute any physical, mental, or emotional
injuries to the INCIDENT? (if your answer is “no,” do not
answer interrogatories 6.2 through 6.7).

{1 6.2 Identify each injury you atiribute to tha INCIDENT and
the area of your body affected.

i Ree ary 1.2008,

FORM INTERROGATORIES—GENERAL Peet(J 630 you sti have any complaints that you attribute to

Oo

Oo

ma

the INCIDENT? If so, for each complaint state:

(@) a description;

(0) whether the complaint is subsiding, remaining the same,
or becoming worse; and

{6) the frequency and duration.

6.4 Did you recelve any consultation or examination

(except from expert witnesses covered by Code of Civil

Procedure section 2034.210-2034.310) or treatment from a

HEALTH CARE PROVIDER for any injury you attribute to

the INCIDENT? If so, for each HEALTH CARE PROVIDER

state:

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

(©) the type of consultation, examination, or treatment
provided;

{©) the dates you received consultation, examination, or
treatment; and

(@) the charges to date.

6.5 Have you taken any medication, prescribed or not, as @
result of injuries that you attribute to the INCIDENT? If 50,
for each medication state:

2) the name;

(2) the PERSON who prescribed or furished it

(0) the date it was prescribed or furnished;

{@) the dates you began and stopped taking it; and

42) the cost to date,

6 Are there any other medical services necessitated by

‘the injuries that you attribute to the INCIDENT that were not

Previously Usted (for example, ambulance, nursing,

Prosthetics)? If so, for each service state:

{@) the nature;

(&) the date:

(©) the cost; and

{@} the name, ADDRESS, and telephone number of each
provider.

6.7 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries
‘that you attribute to the INCIDENT? If so, for each injury
state:

fa) the name and ADDRESS of each HEALTH CARE

PROVIDER;

{0} the compiaints for which the treatment was advised; and
{€) the nature, duration, and estimated cost ofthe treatment.

Property Damage

7.4 Do you attribute any loss of or damage to a vehicle or

‘other property fo the INCIDENT? If so, for each item of

property:

{2) describe the property;

(©) describe the nature and location of the damage to the
Property;

F420

(©) state the amount of damage you are claiming for each
item of property and how the amount was calculated; and

(d) ifthe property was sold, state the name, ADDRESS, and
telephone number of the seller, the date of sale, and the
sale price.

[F722 Has a written estimate or evaluation been made for any
item of property referred to in your answer to the preceding
interrogatory? If so, for each estimate or evaluation state:

{@) the name, ADDRESS, and telephone number of the
PERSON who prepared it and the date prepared;

(0) the name, ADDRESS, and telephone number of each
PERSON who has a copy of it; and

(6) the amount of damage stated.

(_] 7.3 Has any item of property referred to in your answer to

interrogatory 7.1 been repaired? If so, for each item state:

(a) the date repaired;

(b) 2 description of the repair,

(6) the repair cost;

(@) the name, ADDRESS, and telephone number of the
PERSON whi repaired it;

(e) the name, ADDRESS, and telephone number of the
PERSON who paid for the repair.

8.0 Loss of Income or Earning Capacity

L771 8.1 De you attribute any loss of income or eaming capacity
fo the INCIDENT? (if your answer is “no,” do not answer
interrogatories 8.2 through 8.8).

(182 State:
(a) the nature of your work;
(0) your job title at the time of the INCIDENT; and
(c) the date your employment began.

[83 State the last date before the INCIDENT that you worked
for compensation,

84 State your monthly income at the time of the INCIDENT
and how the amount was calculsted,

[185 State the date you retumed to work at each place of
employment following the INCIDENT,

[1 86 State the dates you did not work and for which you lost
income as a result of the INCIDENT.

[J 87 State the total income you have lost to date as a result
of the INCIDENT and how the amount was calculated.

(£1) 8.8 Will you lose income in the future as a result of the
INCIDENT? If so, state:
(@) the facts upon which you base this contention;
(b) an estimate of the amount;
(©) an estimate of how long you will be unable to work: and
(@) howe the claim for future income is calculated.

Fra Rev dana 3 BEDE

FORM INTERROGATORIES—GENERAL Panes9.0 Other Damages

CJ 9.4 _ Are there any other damages that you attribute to the
INCIDENT? If so, for each item of damage state:
42) the nature:
(©) the date it occurred;
(©) the amount; and
{@) the name, ADDRESS, and telephone number of each
PERSON to whom an obligation was incurred.

(J 92 Doany DOCUMENTS support the existence or amount
of any item of damages claimed in interrogatory 9.1? If so,
describe each document and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT.

10.0 Medical History
[J 10.1 At any time before the INCIDENT did you have com-

plaints or injuries that involved the same part of your body

claimed to have been injured in the INCIDENT? If so, for

each state:

{2} a description of the complaint or injury;

{b} the dates it began and ended; and

{c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or
who examined or treated you.

[J 102 List al physical, mental, and emotional disabilities you
had immediately before the INCIDENT. (You may omit
mental or emotional disabiliies untess you attribute. any
‘mental or emotional injury to the INCIDENT.)

10.3 At any time after the INCIDENT, did you sustain
injuries of the kiod for which you are now claiming
domages? Hf so, for each incident giving nse © an injury

iat the date and the place It occurred;

(b} the name, ADDRESS, and telephone number of any
other PERSON involved;

(©) the nature of any injuries you sustained;

(@) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER who you consulted or who
examined or treated you; and

(@) the nature of the treatment and its duration.

11.0 Other Claims and Previous Claims

[J 14.1. Except for this action, in the past 10 years have you
filed an action or made a written claim or demand for
‘compensation for your personal injuries? If so, for each
‘action, claim, or demand state:

2) the date, time, and place and iocation (closest street
ADDRESS or intersection) of the INCIDENT giving rise
to the action, claim, or demand;

(b) the name, ADDRESS, and telephone number of each
PERSON against whom the claim or demand was made
or the action fled:

F120

(c)_ the court, names of the parties, and case number of any
action fled:

(@) the name, ADDRESS, and telephone number of any
attomey representing you:

(e) whether the claim or action has been resolved or is
pending; and

(f)_@ description of the injury.

(2 1122 Inthe past 10 years have you made a written ciaim or
demand for workers’ compensation benefits? If so, for each
claim or demand state:

(@) the date, time, and place of the INCIDENT giving rise to
the claim;

(b) the name, ADDRESS, and telephone number of your
‘employer at the time of the injury;

(©) the name, ADDRESS, and telephone number of the
‘workers’ compensation insurer and the claim number;

(@) the period of time during which you received workers’
‘compensation benefits;

(e) a description of the injury:
the name, ADDRESS, and telephone number of any
HEALTH GARE PROVIDER who provided services: and

(9) the case number at the Workers' Compensation Appeals
Board.

12.0 investigation—General

(.“] 12.1 State the name, ADDRESS, and telephone number of
‘each individual:
{a) who witnessed the INCIDENT or the events occurring
Immediately before or after the INCIDENT;
(0) who made any statement at the scene of the INCIDENT;
(©) who heard any statements made about the INCIDENT by
‘any individual atthe scene; and
(@) who YOU OR ANYONE ACTING ON YOUR BEHALF
caim has knowledge of the INCIDENT (except for
expert witnesses covered by Code of Civil Procedure
section 2034).
[-) 12.2 Have YOU OR ANYONE ACTING ON YOUR BEHALF
interviewed any individual conceming the INCIDENT? if
0, for each individual state:
{@) the name, ADDRESS, and telephone number of the
individual interviewed:
(0) the date of the interview: and
(6) the name, ADDRESS, and telephone number of the
PERSON who conducted the interview.

{123 Have YOU OR ANYONE ACTING ON YOUR BEHALF
obtained a written or recorded statement from any individual
conceming the INCIDENT? if so, for each statement
state:

(@) the name, ADDRESS, and telephone number of the
individual from whom the statement was obtained;

(b) the name, ADDRESS, and telephone number of the
individual who obtained the statement;

(6) the date the statement was obtained; and

(@) the name, ADDRESS, and telephone number of each
PERSON who has the original statement or a copy.

Freee tay 0

FORM INTERROGATORIES—GENERAL

Peas Sohs[>] 124 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any photographs, fims, or videotapes depicting any
place, object, or individual concerning the INCIDENT or
Plaintiffs injuries? If so, state:

() the number of photographs or feet of film or videotape;

(©) the places, objects, or persons photographed, filmed, or
videotaped;

{©) the date the photographs, films, or videotapes were
taken;

(@) the name, ADDRESS, and telephone number of the
individual taking the photographs, films, or videotapes;
and

{@) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the
photographs, films, or videotapes.

[7 125 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any diagram, reproduction, or model of any place or
thing (except for items developed by expert witnesses
covered by Code of Civil Procedure sections 2034.210-

(2) the type (Le., diagram, reproduction, or mode!};

(b) the subject matter; and

(©) the name, ADDRESS, and telephone number of each
PERSON who has it.

[J 128 Was a report made by any PERSON conceming the

INCIDENT? If so, state:

(2) the name, title, identification number, and employer of
the PERSON who made the report

@) the date and type of report made:

{©} the name, ADDRESS, and telephone number of the
PERSON for whom the report was made; and

{@) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the report.

(J 12.7 Have YOU OR ANYONE ACTING ON YOUR
BEHALF inspected the scene of the INGIDENT? If so, for
each inspection state:

{@) the name, ADDRESS, and telephone number of the
Individual making the inspection (except for expert
witnesses covered by Code of Civil Procedure sections
2034.210-2034.310); and

(0) the date of the inspection.

13.0 Investigation—Surveillance
(5) 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF
‘conducted surveillance of any individual invoWed in the
INCIDENT or any party to this action? if so, for each sur-
veillance state:
(2) the name, ADDRESS, and telephone number of the
individual or party;
(©) the time, date, and place of the surveillance;
(©) the name, ADDRESS, and telephone number of the
individual who conducted the surveillance; and
(@) the name, ADDRESS, and telephone number of each
PERSON who has the orginal or a copy of any
surveillance photograph, film, or videotapo,

2034.310) concerning the INCIDENT? If so, for each item state:

F120
[J 13.2 Has a writen report been prepared on the surveillance?
Ifs0, for each witten report state:
(a) tre tile;
(©) the date;
(©) the name, ADDRESS, and telephone number of the
individual who prepared the report; and
(@) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.

14.0 Statutory or Regulatory Violations
[J 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF

contend that any PERSON involved in the INCIDENT
violated any statute, ordinance, or regulation and that the
violation was a legal (proximate) cause of the INCIDENT? If
0, identify the name, ADDRESS, and telephone number of
each PERSON and the statute, ordinance, or regulation that
was violated,

(1) 14.2 Was any PERSON cited or charged with a violation of

any statute, ordinance, or regulation as a result of this

INCIDENT? If so, for each PERSON state:

(a) the name, ADDRESS, and telephone number of the
PERSON;

(b) the statute, ordinance, or regulation allegedly viotated:

(C) whether the PERSON entered a plea in response to the
citation or charge and, if so, the plea entered; and

(@) the name and ADDRESS of the court or administrative
‘agency, names of the parties, and case number.

18.0 Deniais and Special or Affirmative Defenses
[J 18.1. Identify each denial of a materiat allegation and each

special or affirmative defense in your pleadings and for each:

(2) state all facts upon which you base the denial or special
or affimative defense:

(0) stato the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of those facts; and

(©) identity all DOCUMENTS and other tangible things that
‘support your denial or special or affirmative defense, and
state the name, ADDRESS, and telephone number of
the PERSON who has each DOCUMENT.

46.0 Defendant's Contentions—Personal Injury
(J 16.1 _Do you contend that any PERSON, other than you or

plaintiff, contributed to the occurrence of the INCIDENT or

the injuries or damages claimed by plaintif? f so, for each

PERSON:

(@) state the name, ADDRESS, and telephone number of
the PERSON;

{b) state all facts upon which you base your contention;

(©) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts: and

(@) identify all DOCUMENTS and other tangible things that
‘support your contention and state the name, ADDRESS,
‘and telephone number of the PERSON who has each
DOCUMENT or thing.

[) 182 Do you contend that plaintiff was not injured in the

INCIDENT? If so:

(@) state all facts upon which you base your contention;

(b) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and

(©) identty af DOCUMENTS and other tangible things that
‘support your contention and state the name, ADDRESS,
and telephone humber of the PERSON who has each
DOCUMENT or thing.

FE 20 every 1 2008) FORM INTERROGATORIES—GENERAL Page eot8[= 16.3 Do you contend that the injuries or the extent of the
‘injuries claimed by plaintiff as disclosed in discovery
proceedings thus far in this case were not caused by the
INCIDENT? |fso, for each injury:
fe) identify it
{b) state all facts upon which you base your contention;

{) state the names, ADDRESSES, and telephone numbers,
of all PERSONS who have knowledge of the facts; and

{@) Identify all DOCUMENTS and other tangibie things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.

[5 164 Do you contend that any of the services furnished by
any HEALTH CARE PROVIDER claimed by plaintiff in