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Filing # 171729957 E-Filed 04/25/2023 11: 13:50 AM
IN THE CIRCUIT COURT IN AND FOR
JACKSON COUNTY, FLORIDA
CASE NO.
JESSE MOORE,
Plaintiff,
v
FORD MOTOR COMPANY,
Defendant.
/
INTERROGATORIES TO DEFENDANT
NOW COMES Plaintiff, by and through KROHN & MOSS, LTD. and propounds the
following Interrogatories to Defendant, FORD MOTOR COMPANY, (“Defendant”) to be
answered in writing and under oath.
INSTRUCTIONS
1 Answer each interrogatory separately and fully in writing and under oath, unless it
is objected to, in which event the reasons for such objection must be stated in lieu ofan answer.
2 You are under a continuing duty to seasonably supplement your response with
respect to any question when new or additional information becomes known. Additionally, you
are under a continuing duty to seasonably amend a prior response if you learn that the prior
response was incorrect when made, or that the prior response, though correct when made, is no
longer correct or true.
3 Each request to describe or identify a document shall be deemed to include a
request for information sufficient to enable Plaintiff to obtain the document with a subpoena,
including but not limited to the date of the document, a physical description of the document, a
brief description of the content of the document, the identity of the custodian of the document,
the location of the document, and any title given to the document. If an interrogatory calls for a
description of a document, you may, if you prefer, instead of identifying it, attach to your answer
a clear copy, front and reverse of the document.
Electronically File Jackson Case# 23000124CAAXMX 04/25/2023 10:13:50 AM
4 In construing each Interrogatory the present tense includes the past and future
tenses.
55 In construing each Interrogatory, the singular includes the plural, and vice versa
so as to bring within the scope of these requests all information that might otherwise be
construed to be outside its scope.
6. In construing each Interrogatory, the terms “any” and “all” mean “any and all,”
and the terms “each” and “every” mean “each and every.”
7 In construing each Interrogatory, the terms “and” and “or” encompass both “and”
and “or” unless otherwise specified.
8 If you answer any interrogatory by reference to business records, identify such
records by Bates number, or by other readily discernible means of identification, and the name of
the employee certifying the documents as business records for purposes of answering such
interrogatory.
9 If you object to any interrogatory based on a claim of privilege, provide a
statement of the claim of privilege and all facts relied upon in support of that claim, including the
parties involved, any dates involved, the relevant subject matter of the privileged material, any
documents supporting the privileged information, including the dates, authors recipients, title and
subject matter, and present location of any documents included. In the case of attorney work
product privilege, also identify the litigation in connection with which the work product was
prepared.
DEFINITIONS
1 “Defendant,” as identified above, includes Defendant’s present or former
subsidiaries, divisions, sub-divisions, affiliates, joint-ventures, or other business organizations
which Defendant controls, directs, or is otherwise organizationally associated with, as well as ali
of Defendant’s officers, directors, employees, agents, servants, representatives, and/or all other
persons acting or purporting to act on Defendant’s behalf or on behalf of the above listed entities.
2. “You,” “your,” r “your company” means Defendant and your present and former
employees, officers, directors, agents, attorneys, affiliates, subsidiaries, joint ventures,
successors, predecessors, or any person acting or purporting to act on your behalf.
3 “Document” shall be broadly interpreted and means the original and all non-
identical copies of all written or printed items, including without limitation, papers, photographs,
films, recordings, letters, correspondence, communications, memoranda and written notes, legal
pleadings, calendars, diaries, day planners, travel records, lists, outlines, summaries, checks,
check registers, books and accounting, computer cards, printouts, images, and drawings, and all
retrievable information in computer storage, tapes, discs, and records of all types, minutes of
meetings, records of telephone conversations, telegrams, facsimiles, notes, reports, compilations,
notebooks, work papers, graphs, charts, spreadsheets, blueprints, books, brochures, circulars,
manuals, instructions, ledgers, drawings, sketches, photographs, videotapes, audiotapes, films, e-
mails, internal or external websites, compact disks, computer files and disks, sales and
advertising and promotional literature, agreements and all mechanical or electronic data, records
or representations of any kind, studies, books, pamphlets, pictures and voice recordings or every
other device or medium on which or through which information of any type is to be transmitted,
recorded or preserved.
4 “Communicate” or “communication” mean without limitation, oral or written
communications of any kind, such as electronic communications, e-mails, facsimiles, telephone
communications, correspondence, exchange of written or recorded information, or face-to-face
meetings. The phrase “communication between” is defined to include instances where one party
addresses the other party but the other party does not necessarily respond.
5 “Identify,” “identity,” or “identification,” when used in reference to a natural
person, means or requires a statement of the person’s full name and present or last known
address and home telephone numbers, the person’s present or last known position and business
affiliation, business address and telephone number; and a description of the duties and
responsibilities of each position stated.
When used in reference to a document, the terms, “identify, . “identity.” or
“identification” mean or require a statement of the document’s date, title, Bates number (if any),
its subject matter and substance, the location of the document and the custodian of the document,
its author and each addressee and copyee, the type of document (e.g., letter, memorandum,
telegram, chart, computer input or output, photograph, drawing, sound reproduction, etc.) or, if
the above information is not available, some other means of identifying it, its present location,
and the name of each of its present custodians. If the document was, but is no longer, in your
possession or subject to your control, or in existence, state whether it is (a) missing or lost; (b)
has been destroyed; (c) has been transferred, voluntarily or involuntarily, to others; or (d)
otherwise disposed of, and in each instance, explain the circumstances surrounding the
authorization for that disposition of the document and state the date or approximate date of the
disposition.
When used in reference to a division, department, unit or other corporate subdivision, the
oo as
terms, “identify, 1 dentity,” or “identification” mean or require a statement of the name of each
person during the applicable time period who is or was in charge of the activities of the division,
department, unit, or other corporate subdivision, and each of his or her immediate assistants.
When used in reference to communications, the terms, “identify,” “identity,” or
“identification” require a description of all forms of communications, whether in person or
otherwise, written or oral, or by telephone, telex, or other modes of communication, and require
a listing of the senders and recipients, the date of the communication, and an identification of all
documents constituting, relating to, or referring to the subject communication.
6 “Relating to, an 66 referring to, 26, regarding, . or “with respect to” mean, without
limitation, the following concepts: concerning, discussing, describing, reflecting, dealing with,
pertaining to, analyzing, evaluating, estimating, constituting, studying, surveying, projecting,
assessing, recording, summarizing, criticizing, reporting, commenting, or otherwise involving, in
whole or in part.
7
The terms, “describe” or “description,” when referring to a place, thing, or
occurrence, mean to identify with sufficient particularity the place, thing, or occurrence so as to
enable one to locate, examine, and fully comprehend or understand the place, thing, or
occurrence described. When referring to an investigation, the words “describe” or “description,”
refer to the identity of each person who was interviewed in connection with the investigation,
stating the date and place of each interview, the identity of each person present at the interview,
and the identity of each document that records, reflects, or refers to each interview.
8 The term “policy” means each rule, procedure, or directive, formal or informal,
and each common understanding or course of conduct that was recognized as such by you, and
that was in effect at any time during the period covered by these interrogatories.
9 “Including” is used to emphasize certain types of documents requested and should
not be construed as limiting the request in any way.
10. “Or” and “and” should be construed so as to require the broadest possible
interpretation,
i. The term “Mechanical documents” means all Repair Bulletin(s), Service
Builetin(s), Technical Service Bulletin(s), Dealer Service Bulletin(s), Recall(s), Campaign(s),
Special Service Message(s), Technical Assistance document(s) and/or any repair related
communications or documents involving the defects, nonconformities, symptoms and/or
conditions outlined in Plaintiff's Complaint or the subject vehicle’s repair records for the same
make, year and model as the subject vehicle. The term “Mechanical documents” also includes
any document or communication which describes the conditions, defects, or non-conformities in
the subject vehicle as alleged in Plaintiff's Complaint and any investigations relating to the same.
12. The term “Lemon Law documents” means any and all documents relating to State
Lemon Laws and/or Lemon Law advice, the Magnuson-Moss Warranty Act and/or advice
relating to the same, Warranty Administration Manual(s), Warranty Policy Manual(s), Service
Policies and Procedures, Warranty Administration document(s), Lemon Law Situation
documents, Lemon Law Prevention Document(s), Warranty Policy & Procedures, Prevent
Lemon Law Complaint documents, Lemon Law advice and any other document that mentions,
relates to and/or involves Lemon Law documents.
13. The term “subject vehicle” is the vehicle owned or leased by Plaintiff(s) as
detailed in Plaintiff's Complaint.
INTERROGATORIES
1 Identify the individual(s) providing the responses and signing the verification to
these Interrogatories.
2 Identify by article number, date of issuance, description, and components
affected, those Mechanical Documents, as defined above, issued by Defendant for the same year,
make and model vehicle as the subject vehicle that relate to the alleged defects in the subject
vehicle.
3 Identify each employee or agent for Defendant who inspected the subject vehicle,
performed repairs on the subject vehicle, or was present when inspections and/or repairs took
place and describe each individual’s findings or observations relating to the same.
4 Describe the terms of any warranties that Defendant issued, provided, authored, or
extended on the subject vehicle.
5 Identify and describe all communications you made or received relating to any
alleged defect or non-conformity in the subject vehicle.
6 Identify whether Plaintiff, or anyone on Plaintiffs behalf, has ever notified
Defendant that Plaintiff no longer wanted the subject vehicle. If so, state when, whether oral or
written notice was given, and identify each person receiving said statement.
7 Describe and identify the model iype, specifications, options, and components in
the subject vehicle, including, but not limited to, the size of the engine, the type of transmission,
the type of brakes, the weight of the vehicle, safety features in the vehicle, towing capacity, etc.
Note, you may produce a copy of the vehicle’s window sticker to the extent it answers any of the
above.
8 Did Plaintiff abuse, neglect, alter, modify, or misuse the subject vehicle? If your
answer to said interrogatory is “Yes,” describe how Plaintiff abused, neglected, altered,
modified, or misused the subject vehicle and identify and describe all documents and
communications relating to the same.
9. How many cumulative days do Defendant’s records indicate that the subject
vehicle was out of service by reason of any defect, non-conformity, or condition complained of
by Plaintiff?
10. Identify all warranty claims submitted by Defendant’s authorized dealers to
Defendant in which said dealers requested reimbursement for warranty repairs performed on the
subject vehicle and the dollar amount reimbursed for each claim.
ll. Does Defendant have a “good will” repair policy? If the answer to said
interrogatory is “Yes,” describe the policy and identify any repairs that Defendant paid for under
its “good will” program, and identify the reason said repair was paid under a “good will” basis.
12. Identify all repairs performed on the subject vehicle for which Plaintiff was not
charged and the repairs were not covered by Defendant’s warranties on the subject vehicle.
13. Identify all repairs performed on the subject vehicle after the date of its
manufacture, but before the date of purchase by Plaintiff.
14, Identify each of Defendant’s employees or agents who have knowledge of the
repairs, repair attempts, warranty claims, alleged defects or non-conformities, or communications
relating to the repair of the subject vehicle and describe the extent of such knowledge.
15. Define the word “defect” as used in Defendant’s written warranty.
16. Has Defendant failed or refused to reimburse its authorized dealers for any
warranty repairs and/or diagnostic procedures on the subject vehicle? If the answer is “yes,”
state the reason Defendant did not reimburse its dealers for such repair.
17. Did any individuals or agents from Defendant’s authorized dealers contact
Defendant in an effort to seek assistance with the diagnosis or repair of the subject vehicle? If
“yes,” identify all individuals involved and identify and describe all communications.
18. Identify and describe all “Lemon Law documents,” as defined above, that
Defendant provides to its authorized dealerships or to purchasers of Defendant’s vehicles.
19, Identify any document Defendant produced in response to Plaintiff's requests for
production that is not an authentic business record of Defendant or its authorized dealers.
20. Identity an individual within the State of Florida who is employed by Defendant
and who is familiar with the content of all documents authored and produced by Defendant in
response to Plaintiff's Request for Production of Documents and who may be called by Plaintiff
as a witness in Plaintiff's case-in-chief to discuss the documents authored and produced by
Defendant. By the term familiar, Plaintiff means that the witness is able to recognize the
document as a document produced and authored by Defendant and has an understanding of the
contents of the document.
If no single employee of Defendant located within the State of Florida is familiar with the
content of all of the aforementioned documents that were authored and produced by Defendant in
response to Plaintiff's Request for Production, identify all employees located within this state
that collectively are familiar with these documents so that Plaintiff may call these individuals as
witnesses in Plaintiffs case-in-chief, and identify which documents each individual is
knowledgeable.
Respectfully Submitted,
KROHN & MOSS LTD
By /s/Jeremy Kespohl
Jeremy Kespohl
Krohn & Moss, Ltd
10 N Dearbom Street, 3 Floor
Chicago, IL 60602
(312) 578-9428
jkespohl@consumerlawcenter.com
Attorney for Plaintiff
FBN: 0035979
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Filing # 171729957 E-Filed 04/25/2023 11: 13:50 AM IN THE CIRCUIT COURT IN AND FOR JACKSON COUNTY, FLORIDA CASE NO. JESSE MOORE, Plaintiff, v FORD MOTOR COMPANY, Defendant. / INTERROGATORIES TO DEFENDANT NOW COMES Plaintiff, by and through KROHN & MOSS, LTD. and propounds the following Interrogatories to Defendant, FORD MOTOR COMPANY, (“Defendant”) to be answered in writing and under oath. INSTRUCTIONS 1 Answer each interrogatory separately and fully in writing and under oath, unless it is objected to, in which event the reasons for such objection must be stated in lieu ofan answer. 2 You are under a continuing duty to seasonably supplement your response with respect to any question when new or additional information becomes known. Additionally, you are under a continuing duty to seasonably amend a prior response if you learn that the prior response was incorrect when made, or that the prior response, though correct when made, is no longer correct or true. 3 Each request to describe or identify a document shall be deemed to include a request for information sufficient to enable Plaintiff to obtain the document with a subpoena, including but not limited to the date of the document, a physical description of the document, a brief description of the content of the document, the identity of the custodian of the document, the location of the document, and any title given to the document. If an interrogatory calls for a description of a document, you may, if you prefer, instead of identifying it, attach to your answer a clear copy, front and reverse of the document. Electronically File Jackson Case# 23000124CAAXMX 04/25/2023 10:13:50 AM 4 In construing each Interrogatory the present tense includes the past and future tenses. 55 In construing each Interrogatory, the singular includes the plural, and vice versa so as to bring within the scope of these requests all information that might otherwise be construed to be outside its scope. 6. In construing each Interrogatory, the terms “any” and “all” mean “any and all,” and the terms “each” and “every” mean “each and every.” 7 In construing each Interrogatory, the terms “and” and “or” encompass both “and” and “or” unless otherwise specified. 8 If you answer any interrogatory by reference to business records, identify such records by Bates number, or by other readily discernible means of identification, and the name of the employee certifying the documents as business records for purposes of answering such interrogatory. 9 If you object to any interrogatory based on a claim of privilege, provide a statement of the claim of privilege and all facts relied upon in support of that claim, including the parties involved, any dates involved, the relevant subject matter of the privileged material, any documents supporting the privileged information, including the dates, authors recipients, title and subject matter, and present location of any documents included. In the case of attorney work product privilege, also identify the litigation in connection with which the work product was prepared. DEFINITIONS 1 “Defendant,” as identified above, includes Defendant’s present or former subsidiaries, divisions, sub-divisions, affiliates, joint-ventures, or other business organizations which Defendant controls, directs, or is otherwise organizationally associated with, as well as ali of Defendant’s officers, directors, employees, agents, servants, representatives, and/or all other persons acting or purporting to act on Defendant’s behalf or on behalf of the above listed entities. 2. “You,” “your,” r “your company” means Defendant and your present and former employees, officers, directors, agents, attorneys, affiliates, subsidiaries, joint ventures, successors, predecessors, or any person acting or purporting to act on your behalf. 3 “Document” shall be broadly interpreted and means the original and all non- identical copies of all written or printed items, including without limitation, papers, photographs, films, recordings, letters, correspondence, communications, memoranda and written notes, legal pleadings, calendars, diaries, day planners, travel records, lists, outlines, summaries, checks, check registers, books and accounting, computer cards, printouts, images, and drawings, and all retrievable information in computer storage, tapes, discs, and records of all types, minutes of meetings, records of telephone conversations, telegrams, facsimiles, notes, reports, compilations, notebooks, work papers, graphs, charts, spreadsheets, blueprints, books, brochures, circulars, manuals, instructions, ledgers, drawings, sketches, photographs, videotapes, audiotapes, films, e- mails, internal or external websites, compact disks, computer files and disks, sales and advertising and promotional literature, agreements and all mechanical or electronic data, records or representations of any kind, studies, books, pamphlets, pictures and voice recordings or every other device or medium on which or through which information of any type is to be transmitted, recorded or preserved. 4 “Communicate” or “communication” mean without limitation, oral or written communications of any kind, such as electronic communications, e-mails, facsimiles, telephone communications, correspondence, exchange of written or recorded information, or face-to-face meetings. The phrase “communication between” is defined to include instances where one party addresses the other party but the other party does not necessarily respond. 5 “Identify,” “identity,” or “identification,” when used in reference to a natural person, means or requires a statement of the person’s full name and present or last known address and home telephone numbers, the person’s present or last known position and business affiliation, business address and telephone number; and a description of the duties and responsibilities of each position stated. When used in reference to a document, the terms, “identify, . “identity.” or “identification” mean or require a statement of the document’s date, title, Bates number (if any), its subject matter and substance, the location of the document and the custodian of the document, its author and each addressee and copyee, the type of document (e.g., letter, memorandum, telegram, chart, computer input or output, photograph, drawing, sound reproduction, etc.) or, if the above information is not available, some other means of identifying it, its present location, and the name of each of its present custodians. If the document was, but is no longer, in your possession or subject to your control, or in existence, state whether it is (a) missing or lost; (b) has been destroyed; (c) has been transferred, voluntarily or involuntarily, to others; or (d) otherwise disposed of, and in each instance, explain the circumstances surrounding the authorization for that disposition of the document and state the date or approximate date of the disposition. When used in reference to a division, department, unit or other corporate subdivision, the oo as terms, “identify, 1 dentity,” or “identification” mean or require a statement of the name of each person during the applicable time period who is or was in charge of the activities of the division, department, unit, or other corporate subdivision, and each of his or her immediate assistants. When used in reference to communications, the terms, “identify,” “identity,” or “identification” require a description of all forms of communications, whether in person or otherwise, written or oral, or by telephone, telex, or other modes of communication, and require a listing of the senders and recipients, the date of the communication, and an identification of all documents constituting, relating to, or referring to the subject communication. 6 “Relating to, an 66 referring to, 26, regarding, . or “with respect to” mean, without limitation, the following concepts: concerning, discussing, describing, reflecting, dealing with, pertaining to, analyzing, evaluating, estimating, constituting, studying, surveying, projecting, assessing, recording, summarizing, criticizing, reporting, commenting, or otherwise involving, in whole or in part. 7 The terms, “describe” or “description,” when referring to a place, thing, or occurrence, mean to identify with sufficient particularity the place, thing, or occurrence so as to enable one to locate, examine, and fully comprehend or understand the place, thing, or occurrence described. When referring to an investigation, the words “describe” or “description,” refer to the identity of each person who was interviewed in connection with the investigation, stating the date and place of each interview, the identity of each person present at the interview, and the identity of each document that records, reflects, or refers to each interview. 8 The term “policy” means each rule, procedure, or directive, formal or informal, and each common understanding or course of conduct that was recognized as such by you, and that was in effect at any time during the period covered by these interrogatories. 9 “Including” is used to emphasize certain types of documents requested and should not be construed as limiting the request in any way. 10. “Or” and “and” should be construed so as to require the broadest possible interpretation, i. The term “Mechanical documents” means all Repair Bulletin(s), Service Builetin(s), Technical Service Bulletin(s), Dealer Service Bulletin(s), Recall(s), Campaign(s), Special Service Message(s), Technical Assistance document(s) and/or any repair related communications or documents involving the defects, nonconformities, symptoms and/or conditions outlined in Plaintiff's Complaint or the subject vehicle’s repair records for the same make, year and model as the subject vehicle. The term “Mechanical documents” also includes any document or communication which describes the conditions, defects, or non-conformities in the subject vehicle as alleged in Plaintiff's Complaint and any investigations relating to the same. 12. The term “Lemon Law documents” means any and all documents relating to State Lemon Laws and/or Lemon Law advice, the Magnuson-Moss Warranty Act and/or advice relating to the same, Warranty Administration Manual(s), Warranty Policy Manual(s), Service Policies and Procedures, Warranty Administration document(s), Lemon Law Situation documents, Lemon Law Prevention Document(s), Warranty Policy & Procedures, Prevent Lemon Law Complaint documents, Lemon Law advice and any other document that mentions, relates to and/or involves Lemon Law documents. 13. The term “subject vehicle” is the vehicle owned or leased by Plaintiff(s) as detailed in Plaintiff's Complaint. INTERROGATORIES 1 Identify the individual(s) providing the responses and signing the verification to these Interrogatories. 2 Identify by article number, date of issuance, description, and components affected, those Mechanical Documents, as defined above, issued by Defendant for the same year, make and model vehicle as the subject vehicle that relate to the alleged defects in the subject vehicle. 3 Identify each employee or agent for Defendant who inspected the subject vehicle, performed repairs on the subject vehicle, or was present when inspections and/or repairs took place and describe each individual’s findings or observations relating to the same. 4 Describe the terms of any warranties that Defendant issued, provided, authored, or extended on the subject vehicle. 5 Identify and describe all communications you made or received relating to any alleged defect or non-conformity in the subject vehicle. 6 Identify whether Plaintiff, or anyone on Plaintiffs behalf, has ever notified Defendant that Plaintiff no longer wanted the subject vehicle. If so, state when, whether oral or written notice was given, and identify each person receiving said statement. 7 Describe and identify the model iype, specifications, options, and components in the subject vehicle, including, but not limited to, the size of the engine, the type of transmission, the type of brakes, the weight of the vehicle, safety features in the vehicle, towing capacity, etc. Note, you may produce a copy of the vehicle’s window sticker to the extent it answers any of the above. 8 Did Plaintiff abuse, neglect, alter, modify, or misuse the subject vehicle? If your answer to said interrogatory is “Yes,” describe how Plaintiff abused, neglected, altered, modified, or misused the subject vehicle and identify and describe all documents and communications relating to the same. 9. How many cumulative days do Defendant’s records indicate that the subject vehicle was out of service by reason of any defect, non-conformity, or condition complained of by Plaintiff? 10. Identify all warranty claims submitted by Defendant’s authorized dealers to Defendant in which said dealers requested reimbursement for warranty repairs performed on the subject vehicle and the dollar amount reimbursed for each claim. ll. Does Defendant have a “good will” repair policy? If the answer to said interrogatory is “Yes,” describe the policy and identify any repairs that Defendant paid for under its “good will” program, and identify the reason said repair was paid under a “good will” basis. 12. Identify all repairs performed on the subject vehicle for which Plaintiff was not charged and the repairs were not covered by Defendant’s warranties on the subject vehicle. 13. Identify all repairs performed on the subject vehicle after the date of its manufacture, but before the date of purchase by Plaintiff. 14, Identify each of Defendant’s employees or agents who have knowledge of the repairs, repair attempts, warranty claims, alleged defects or non-conformities, or communications relating to the repair of the subject vehicle and describe the extent of such knowledge. 15. Define the word “defect” as used in Defendant’s written warranty. 16. Has Defendant failed or refused to reimburse its authorized dealers for any warranty repairs and/or diagnostic procedures on the subject vehicle? If the answer is “yes,” state the reason Defendant did not reimburse its dealers for such repair. 17. Did any individuals or agents from Defendant’s authorized dealers contact Defendant in an effort to seek assistance with the diagnosis or repair of the subject vehicle? If “yes,” identify all individuals involved and identify and describe all communications. 18. Identify and describe all “Lemon Law documents,” as defined above, that Defendant provides to its authorized dealerships or to purchasers of Defendant’s vehicles. 19, Identify any document Defendant produced in response to Plaintiff's requests for production that is not an authentic business record of Defendant or its authorized dealers. 20. Identity an individual within the State of Florida who is employed by Defendant and who is familiar with the content of all documents authored and produced by Defendant in response to Plaintiff's Request for Production of Documents and who may be called by Plaintiff as a witness in Plaintiff's case-in-chief to discuss the documents authored and produced by Defendant. By the term familiar, Plaintiff means that the witness is able to recognize the document as a document produced and authored by Defendant and has an understanding of the contents of the document. If no single employee of Defendant located within the State of Florida is familiar with the content of all of the aforementioned documents that were authored and produced by Defendant in response to Plaintiff's Request for Production, identify all employees located within this state that collectively are familiar with these documents so that Plaintiff may call these individuals as witnesses in Plaintiffs case-in-chief, and identify which documents each individual is knowledgeable. Respectfully Submitted, KROHN & MOSS LTD By /s/Jeremy Kespohl Jeremy Kespohl Krohn & Moss, Ltd 10 N Dearbom Street, 3 Floor Chicago, IL 60602 (312) 578-9428 jkespohl@consumerlawcenter.com Attorney for Plaintiff FBN: 0035979