Preview
1 ROB BONTA
2
Attorney General of Califomia
RUSSELL B. HiLDRETH
FiIEB/£1^00RS!ED
Supervising Deputy Attomey General
3 ANDREA M . KENDRICK State Bar No. 225688 SEP 2 8 2022
COURTNEY S. COVINGTON, State Bar No. 259723
4 Deputy Attomeys General By:. E. Macdnnalri
13001 Street, Suite 125 Deputy Clerk
5 P.O. Box 944255
Sacramento, CA 94244-2550
6 Telephone: (916)210-7821
Fax: (916)327-2319
7 E-mail: Ajndrea.Kendrick@doj.ca.gov
8 Attorneys for Defendants Exempt from Filing Fees
Pursuant to Gov. Code § 6103
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SACRAMENTO
11
12
13 FIRE GUARD CORPORATION; Case No. 34-2019-00249221-CU-CR-GDS
RAHMAN BRIAN SHAHANGIAN, an
14 individual; and CALIFORNIA FIRE DECLARATION OF ANDREA M.
PROTECTION COALITION, a California KENDRICK IN SUPPORT OF
15 Corporation; and JUAN CARLOS DEL DEFENDANTS' MOTION (A) TO
TORO TREJO, an individual, COMPEL PLAINTIFFS FIRE GUARD
16 CORPORATION, BAHMAN BRIAN
Plaintiffs, SHAHANGIAN, AND JUAN CARLOS DEL
17 TORO TREJO TO PROVIDE RESPONSES
V. TO (1) SPECIAL INTERROGATORIES
18 (SET ONE), (2) FORM
INTERROGATORIES (SET ONE); AND (3)
19 CALIFORNIA DEPARTMENT OF REQUESTS FOR PRODUCTION OF
FORESTRY AND FIRE PROTECTION; DOCUMENTS (SET ONE); AND (B) FOR
20 CALIFORNIA OFFICE OF THE STATE AN ORDER DEEMING ADMITTED THE
FIRE MARSHAL; MIKE RICHWINE, in REQUESTS FOR ADMISSION (SET ONE)
21 his official capacity as State Fire Marshal;
JEFFERY SCHWARTZ, in his official Date: October 27, 2022
22 capacity as Deputy State Fire Marshal; and Time: 1:30 p.m.
DOES 1 through 10, inclusive, Dept.: 53
23 Trial Date: December 18, 2023
Defendants. Action Filed: January 25, 2019
24
Reservation No.: 2663593
25
26
27
28
1
Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221)
1 I, Andrea M. Kendrick, declare:
2 1. I am an attomey licensed to practice in all of the courts in the State of Califomia and
3 a Deputy Attomey General in the Califomia Attomey General's Office, counsel of record for
4 defendants in this action. I have personal knowledge of all the matters set forth herein and, if
5 called as a witness, I could and would competently testify thereto.
6 2. Attached as Exhibit A is a tme and correct copy of the Special Interrogatories (Set
7 One), Form Interrogatories (Set One), Request for Producdon of Documents (Set One), and
8 Requests for Admission (Set One), that defendant Office of the State Fire Marshal (OSFM)
9 served on plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del
10 Toro Trejo (collectively, Fire Guard and the Individual Plaindffs), on August 28. 2020.
11 3. Attached as Exhibit B are tme and correct copies of emails between counsel for Fire
12 Guard and the Individual Plaintiffs and me in which Fire Guard and the Individual Plaintiffs
13 requested an extension to November 2, 2020, to respond to the discovery requests, and an email
14 from me granting the request.
15 4. Fire Guard and the Individual Plaintiffs did not object to or respond to any of the
16 discovery requests nor did they seek or receive another extension of time before or on November
17 2, 2020, to respond.
18 5. In December 2020, the parties agreed on a stay of discovery until the end of January
19 29, 2021, which was ultimately extended to the last part of 2021.
20 6. During the stay, counsel for Fire Guard and the Individual Plaintiffs requested
21 confirmation that his client could respond to the outstanding discovery after the stay. Attached as
22 Exhibit C is a tme and correct copy of an email from me to counsel for Fire Guard and the
23 Individual Plaindffs confirming that when the stay on discovery ends, the OSFM reserved its
24 right to seek appropriate relief regarding Fire Guard and the Individual Plaintiffs' failure to
25 respond to the outstanding discovery on or before the November 2, 2020, due date.
26 7. Attached as Exhibit D is a tme and correct copy of a letter from me to counsel for
27 Fire Guard and the Individual Plaintiffs, dated January 11, 2022, in which the OSFM requested
28
2
Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221)
1 that Fire Guard and the Individual Plaintiffs respond to the OSFM's discovery requests on or
2 before Febmary 10, 2022, and that if they did not the OSFM would seek relief from the Court.
3 8. Counsel for Fire Guard and the Individual Plaintiffs did not respond to the letter
4 attached as Exhibit D.
5 9. Attached as Exhibit E is a tme and correct copy of an email from me to counsel for
6 the Individual Plaintiffs dated March 8, 2022, asking counsel for Fire Guard and the Individual
7 Plaintiffs whether they provided a response to the outstanding discovery requests.
8 10. As of the date of the filing of this motion. Fire Guard and the Individual Plaintiffs
9 have not responded to the OSFM's discovery requests or to my January 11, 2022 letter or my
10 March 8, 2022 email regarding responding to discovery.
11 I declare under penalty of perjury under the laws of the State of Califomia that the
12 foregoing is tme and correct.
13 Executed on September 28, 2022, in Gait, Califomia.
14
Andrea M. Kendrick
15
16
17 SA2019300028
36465797.docx
18
19
20
21
22
23
24
25
26
27
28
Declaradon of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221)
1 EXHIBIT LIST
2
3 A Special Interrogatories (Set One)
Form Interrogatories (Set One)
4
Request for Production of Documents (Set One)
5 Request for Admission
6 Served by Defendant Office of the State Fire Marshal (OSFM) on plaintiffs Fire
Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del Toro Trejo
7 (collectively, Fire Guard and the Individual Plaintiffs), on August 28, 2020
8
B Email communications between Timothy Kassouni, counsel for Fire Guard and
9 the Individual Plaintiffs, and Andrea M. Kendrick, counsel for defendants
10
C Email communication between Andrea M. Kendrick, coimsel for defendants, to
11 Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs
12
D Letter dated January 11, 2022, from Andrea M. Kendrick, counsel for defendants,
13 to Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs
14
E Email dated March 8, 2022, from Andrea M. Kendrick, counsel for defendants, to
15 Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs
16
17
18
19
20
21
22
23
24
25
26
27
28
Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221)
Exhibit A
1 XAyiERBECERRA
AttOiTiey Gehei'ail of Galiforhia
2 TkAcY L. WJNSOR
Supervising Deputy Attomey General
3 ANDREA M . KENDRICK, State Bar No. 225688
RUSSELL;B. HiLDRETH, State Bar No. 166167
4 Deputy Attorney Genieral
State Bar No. 225688
5 13001 Street, Suite 125
P.O. Box 944255
6 Sacramento, CA 94244-2550
Telephone: (916)210-7821
.7 Fax: (916) 327-2319
E-mail:; Andrea.K^
8 Attomeys for Deferidgnts
9
SUPERIOR COURT OF THE STATE OF GALIFORNIA
10
COUNTY OF SACRAMENTO
II
12
13 FIRE GUARD CORPORATION; Case No, 34-2019-00249221
BAHMAN BRIAN SHAHANiGIAN, an
14 individual; CALIFORNIA FTOE SPECIAL INTERROGATORIES t o
PROTECTION COALITiON, a California PLAINTIFFS FIRE GUARD
15 Corporation; arid JUAN CARLOS DEL CORPORATION, BAHMAN BRIAN
TORO TREJO, an individual, SHAHANGIAN, and JUAJS CARLOS
16 DEL TORO TREJO (SET ONE)
Plalntififs,
17
18
19 CALIFORNIA DEPARTMENT OF
FORESTRY AND FIRE PROTECTION;
20 CALIFORNIA OFFICE OF THE STATE
FIRE MARSHAL; MIKE RICHWINE, in
21 his ofRcial capacity as State Fire Marshall;
JEFFREY SCHWARTZ, in his official
22 capacity as Deputy State Fire Marshal; arid
D O E S 1 through 10, inclusive,
23
Defendants;,
24
25
PROPOUNDING PARTY: Defendant pfifice of the State Fire, Marshal
26
RESPONDING PARTY: Plaintiffs Fire Guard Gpiporation, Bahnian Brian Shahangian, and
27 Juan C!arjos Del Toro Trejo
28 SET NO. ONE (1)
Special Interrogatories to Plaintiffs Fire Guard Corp-^ Shahangian, and Trejo (One) (34-2019.-00249221)
1 Pursuant to Godei of Civil Procedure section 2030.010 et seq., yiDu or ybiif legal
2 iepresehtatives are required to resppnd to the follpvving special interrogatories, separately and iri
:3 Y^ting xinder oath, wHthih 30 d
4 SPECIAL INTERROGATORIES
5 iSPECIAL iNTEimbGATORY NO. 1;
6 Identify ijy hahie,title;,and address, all OFFICERS, (as used heirein, the terms "OFFICER"
7 and "OFFICER(s)", shall mean any indiyidual person holding a position of executive manageriient
'8 within a corporatioii, incMdlng biit not limited to the pfesideiit, vice-president, chief executive
9 officer, chieffinancialofficer, and/or secretary) and directors of FIRE GUARD (as used herein,
10 the term "FIRE GU ARD"'refers, to plaintiff Fire Guard Corporation) froiii January 1, 2013, 'to, tiie
11 present:
12 iSPECiAL INTERROGATORY NO. 2:
13 State whether or npt each person identified in YOUR respprise tp Special intep-pgatoiy
14 No. 1 recdved any DOGUMENTS (as used, herein, the tehns "DOCUMENT' or
15 "PpCUMENTS" shall mean any and all written, printed, recprded, graphic, or photographic
16 materials of any kind or description, as defined in Eyidence Code sectipn 250, including without
17 limitation electronic and hardcopy dpciiments) from the OSFM (as used herein, "OSFM" refers to
18 defendant Office ofthe State Fire Marshal) regarding the REGULATIONS (as used herein, the
19 terra "REGULATIONS," mearis the Aiitomatic Fire Extingtaishing Systems Certification
20 regulations, Califoiiiia Code pf Reguiations, title 19, Chapter 5.5.).
21 SPECIAL INTERROGATORY NO. 3:
22 I f ariy person YOU identified in YOUR response tp Special Interrogatory No. 1, received
23 any DOCUMENT from the OSFM regarding the REGULATIONS, IDENTIFY EACH
24 DOCXJMENT (as used hei-ein, the term "IDENTIFY EACH DOCUMENT,", means to describe
25 the DOCUMENT with sufficient specificity to allow the OSFM to know what and where the
26 DOCUMENT is, iticluding: (1) the date of the DOCUMENT, (2) the author(s) of the,
27
28
2
Special Iriterrogatorieis to Plaintiffs Fire Guard Corp., Shahangian, and Trejo (One) '(34-2019-00249221)
1 POGUMENT, if known; (3) the type bf DOCUMENT (e.g., letter, report^ notice, etc.); (4) the
.2 name of the person who received the pOGUMENT); and (5) th_e custpdian of the pOGUMENt)
.3 that person .received.
4 SPECIAL INTERROGATORY NO. 4;
5 .State whether orriotFIRE GUARD received any DOCUMENTS from the OSFM
6 regarding the REGULATIONS.
7 SPECLiL INTERROGATORY NO. 5:
8 I f FIRE GUARD ireceived any DOCUMENTS from tiie OSFM regarding the
9 REGULATIONS, IDENTIFY EACH DOCUMENT tiiat FIRE GUARD received,
10 SPECIAL INTERROGATORY No. 6:
11 State the mahrier in which FIRE GUARD aiid each of its OFFICERS and directprs
12 became aware of the final adopted REGULATIONS.
13 SPECIAL INTERROGATORY NO. 7;
14 State the names and addresses Pf all employees Pf FIRE GUARD from January 1,2013, to
15 the present.
16 SPECIALINTERROGATORY NO. 8;
i7 State whether or hot plaintiff Bahman Brian Shahangian received any pOCUMENTS
18 from the OSFM regarding the REGULATIONS.
19 SPECIAL INTERROGATORY NO. 9:
20 I f plaintiff Bahman Brian Shahangian received any DOCUMENTS from tiie OSFM
21 regarding tiie REGULATIONS, IDENTIFY EACH DOCUMENT that Mr. Shahangian received.
22 SPECIAL INTERROGATORY NO. 10:
23 State vvhether or not plaintiff Juan Carlos Del Toro Trejo received any DOCUMENTS
24 from tiie OSFM regarding tiie REGULATIONS.
25 SPECIAL INTERROGATORY NO. 11;
26 If plaintiff Juan Carlos Del Toro Trejo received any DOCUMENTS from the OSFM
27 regarding the REGULATIONS, IDENTIFY EACH DOCUMENT that Mr. Trejo received.
28
3
Special Interrogatories to Plaintiffs Fire Guard Co^p., Shahangian, and Trejo (One) (34-2019-00249221)
1 SPECIAL INTERROGATORY NO. 12:
2 :State all facts that support YOUR cpntentipn in Paragraph 26 of the jFIRST AJVIENpEp
3 COMPLAINT (as used herein, the.teriri "FIRST AMENDED COMPLAINT" means the First
-4 Ameiaded Complairit for Declaratpiy # d Injimcti^ Relief, filed by plaintiffs Fire Guard
5 CPrpPfatipn, Bahman Briain Shahaiigiati, CalifoiTiia Fire Protection Coalition, and Jiian Garlps
?6 Del Toro Trejo, in Sacrarnento County Superior Court, case number 34-2019-0024922 Pf
7 iabout May 2, 2019) that in the-case herein, the "licensirig system requires extetisiye testing or
8 educatipn pitiy tangentially related to an applicant's fitness to practice his or her chosen
9 . occupation."
10 SPECIAL INTERROGATORY NO. 13:
11 Identify each witness Ayith knowledge that siipipoits YOUR Cpriteritibn in Paragraph 26 of
12 the FIRST A M E N P E D COMPLAINT that iri the case herein, the "Ucensing system requires
13 extensive testing br education only tangentially related tb an applicant's fitness to practice his or
14 her chosen occupation."
15 SPECIAL INTERROGATORY NO. 14;
16 IDENTIFY EACH DOCUMENT which supports YOUR contentipri iri.Paragraph 26 pf
17 the FIRST AMENDED COMPLAINT tiiat m the case herein, the "licensing system requires
18 extensive testing or educatibn only tarigentialiy related to an applicant'sfitnessto practice his or
19 her chosen bcciipatioh."
20 SPECIAL INTERROGATORY NO. 15:
21 State ail factstiiat.supportYOUR contention in Paragraph 26 ofthe FIRST AMENDEP
22 COMPLAINT that in the case herein, the "licensing systein . . . . has a tenuptis cbririectibn tb the
23 protection of the public''
24 SPECIAL INTERROGATORY NO. 16:
25 Identify by name, title, and address, each witoess with knowledge that suppprts YOUR
26 coiitentipn in Paragraph 26 oftiieFIRST AMENDED COMPLAINT tiiat intiiecase herein, tiie
27 "licensing system.,. has a tenugiis connectipn to the protection of the piiblic."
28
4
Special Interrogatories to Plaintiffs Fire Guard Corp., Shahangian. and Trejo (One) (34-2019-00249221)
1 SPECIAL INTERROGATORY NO. 17:
2 IDENTIFY EACH DOCUMENT which suppprts YOUR cpntentipii in Paragraph 26 of
3 the FIR5T AMENDED COMPLAINT tiiat iri the case herein, the "hcerisirig systeiri... has a
4, teritioiis cbnnectibri to the protection of the public/'
5 SPECIAL INTERROGATORY NO. 18;
.6 State all facts that support YOUR, contentipn in Paragraph 27 of Jhe FIRST AMENDED
7 COMPLAINT that in tiie case herein, "the burdeii of licensure reqiiirerrieiits is greatly out of
8 'pfbpbrtion with alleged public beriefits cfeatied by those requirements.''
9 SPECIAL INTERROGATORY NO. 19:
:10 Identify by name, title, and address, each vvitness with knowledge that supports YOUR
11 cpntentipn in Paragraph 27 pf tiie FIRST AMENDED COMPL AINT that in tiie case herein, "tiie
12 burden of licensure requirements is greatly out of propprtion with alleged public benefits created
13 by thpse requirements."
14 SPECIAL INTERROGATORY NO. 20:
;i5 IDENTIFY EACH POCUMENT which supports YOUR contention in Paragraph 2? of
16 the FIRST AMENDED COMPLAINT that m tiie case herein, "tiie burden pf licensure
17 reqiiireriients is grieatly put bf propbrtibri with alleged public beriefits created by those
18 requirements."
19 SPECIAL INTERROGATORY NO. 21:
20 State all facts that support YOUR cbritention m Paragraph 50 bf the FIRST AMENDED
2i COMPLAINT that"' [t]he regulatory scheme impairs the contiactual rights of existing C-16
22 license holders, who have executed confracts for cbnunercial sprinkler work without actual notice
23 of the regulatory scheriie or ifs grandfathering timeframes;"
24 SPECIAL INTERROGATORY NO. 22:
25 Identify by name, title, and address, each witaess with knowledge that supports YOUR
26 cpnteiitipn in Paragraph 50 oftiieFIRST AMENDED COMPLAINT tiiat '" [t]he regulatory
27 scheme impairs the contractual rights of existing C-16 license holders, who have executed
28
5
Special Interrogatories to Plaintiffs Fire Guard Corp., Shahiangian, and Trejo (One) (34-2019-00249221)
1 contracts for eonimercial sprinkler wprjk withptit actualripticebf the reguiatbry schexrie or its
% grandfatheririg tiniefrariles."
3 SPECIAL INTERROGATORY NO. 23:
4 IDENTIFY EACH POCUMENt whict supports in YOUR contention in Paragraph 50 of
-5 tiie FIRST AMENDED COMPLAINTtiiat"'it]he regulatory scheme impairs the cbntiactiial
6 rights bf existing C-l 6 licerise hblders, who have executed confracts for conimercial sprinkler
7 work vwthbut actual notice ofthe regulatory scherne or its grandfathering timefiumes."
8 SPECIAL INTERROGATORY NO. 24;
9 Identify by the names of tiie contracting piarties and the date(s) bf execution, each
10 cbritiactuai agreetrierit Which YOU contend in paragraph 51 pf the FIRST AMENpED
11 COMPLAINT, is "unpaired by the regulatory schenie;"
12
13 Dated: August 28, 2020 Respectfully Submitted,
14 XAVIER BECERRA
Attpmey Cierieral Pf Califomia
15 TRACY L. WINSOR
16 Supervising Deprify Attorriey General
17
18
ANDREA M. KENDRICK
19 Deputy Attomey General
Attorneys for Defendants
20
21 SA20.19300028
3432408 l.docx
22
23
24
25
26
27
28
Special IriteiTOgatories to Piairitiffs Fire Guard Corp., Shahangian, and Trejo (One) (3472019-00249221)
DECLARATION OF SERVICE BY E-MAIL and U.S. MAIL
Case Name: Fire Guard Gprporatipn, et al. v. California D
Fire Prbtectidri, et al.
Case No.: I^acrariieritb County Superior Gourt Case No. 34^2Cil9-6624922i
1 deciafe:
I arn enipibyed.in the Office of the Attpmey •Qenefa^ which is the office pf a meri^^^ the
'California State.Bar; at which meniber's direction this service is made, fam I8.yeai-s of age or
bld^r. and nbt'a party t^ this matter; I. am,familiaivwith the bus^ Office of the
Attorriey General for cbllectibri arid.pi'bcessirig^b fbf irriailmg with the United
States P.pstal Service.- in accordance with that- practice, cprrespondericc;placed iri the iritemal
mail epiiectipri.sy^^^ withlhe UnitbdiStates
Postal Service with postage thereon fully prepaid that sa'me'day m the ordinary course of
husiries's.
On August 28. 2020.1 served the attached Special Interrogatories to Plaintiffs Fire Guard
Corppratipii, Bahihan Brian Shahangiari, |in^ juari Carlos Del Tprp Trejo (Set ,Oiie) by
placing a true copy tiierepf enclosed in a sealed envelope, in the interilal niail systerri bf the
^Office of the Attorney Geneml, addressed as follows:
Tirnpthy V, .Kasspurii
Attorney at Law
Kassouni Law
621 Capitol Mall, Suite-2p25
Sacfamento, GA '^5814.
timothv(fl),kassounilaw.com
In addition, on August 28. 2020.1 served the attached Special Interrogatories to iPlairitiffs Fire
Guard Corporation, Bahniian Brian Shahangian, and Juan Carlos Del Tpro Trejo (Set
One) by trarisrnittirig a triie copy via electrbrii tb:
Margaret Esquifbz, Esq.
49i4 Balboa Boulevard, #500
Encinp. CA 91316-3402
esc]uiroz(a),piri.me
I declare under penalty of perjury under the laws of the State Of Califprnia and the United States
of America the foregoing is true and correct and that this declaratiori was executed bn August 28,
2020, at Sacrarrieritp, California.
Ann-Marie.Doersch
Declarant \-y ^igriatufe
SA2ai')]ooo:3
34361 lOO.docx
DISC-001
ATTORNEY OR PW^T/ wmnOU^ Sfafe earnumter, sndaddressj;
Andrea M; Kendrick (SBN 22568.8)
Califdiriia Department bf Justice
1300 1 Street. Suite 125 Sacramento, GA 951514
TELEPHONENO.: (916)210-7821
FAX NO. pptidnal): (916) 327,-2319
E-MAIL ADDRESS (Optional): Andrea.Kendrick@dbj.ca.gov
ATTORNEY FOR (wa/ne): Defendants California Department of Forestry and Fire Protection, et al.
SUPERIOR couRTiOF dALiFiDRNiA. couNTV OF Sacrame^^
SHORT TITLE OF CASE:
Fire Guard Corporation, et al. v. Califomia Departrnerit of Forestry and Fire Protection, et al.
FORM INTERROGATORIES—GENERAL CASE NUMBER;
34^2019^00249221
Asking Party: Defendant Office of the State Fire Marshal
A n s w e r i n g Party:, Plaintiffe Fire Guard Corp., Mr. SHahangiah, and Mr. Trejo
Set No.: One
Sec. 1. instructions to All Parties Each ansvyer must be as complete and.straightforward as
(aj jnterrpgatorjes are written questions prepared by a party to an the information reasonably available to ygli, includirig the.
action that are sent to any other party in the actipn to be itiforrriatiori possessed by your attomeys or agerits, permits.
ansvyered under oath. The interrogatories bejow are forrn If an interrogatory cannot be answered completely, answer it
ihterrogatpries approved fpr use in ciyi| cases. to the extent possible.
(b) For time limitations, requirernents for sen/ice ph other parties, (d) |f you do not have enough personal knowledge to fully
and other details, see Code of Cjvil Procedure sections answer an interrogatory, say so, but make a reasonable and
2030.01 (>^2b30.410 and the cases construing those sections. good faith effort to get the information by asking other
(c) These form interrogatories do not change existing law persons or organizations, unless the infpntiatidri is equally
relating to interrogatories nor do they affect an answering available tp the asking party.
party's right to assert any privilege or niake any objection^
(e) Whenever an interrogatory rriay be ansyyered by referring to
Sec. 2. Instructions to the Asking Party a dpcurnent, the dociiment may be attached as an exhibit to
(a) These interrogatories are designed for optional use by parties the response and referred to in the response. If the.
in unlimited civil cases where the amount demarided exceeds document has more than.one page, refer to the jsage and
$25,000. Separate interrogatories, Form Interrogatories— sectibri where the arisyyer to the interrogatory can be fpund.
Lirnited Civil Cases.(Economic Litigation) (form blSC-004), Whenever an address arid telephone number for the same
(f)
which have no subparts, are designed for use in limited civil person are requested in more than one interrogatory, you
cases where the amount demanded is $25,000 or less; are required to furnish them in answering only the first
however, those interrogatories may also be used in unlimited interrogatory asking for that informatibri,
civil cases.
(b) Check the box next to each interrogatory that you want the (g) If you are asserting a privilege or making an objection to an
ariswerihg party to answer. Use care in choosing those interrogatory, you must specifically assert the privilege bi"
interrogatories that are appiicabie to the case. state the objection iri your written resporise.
(c) You may insert your own definition of INCIDENT in Section 4, (h) Your answers to these interrogatories muist be verified,
but only where the action arises from a ciourse of conduct or a dated, and signed. You may wish to use the following form
series of events occurring over a period pf time, at the end of your aniswers:
(d) t h e inten'ogatories in section 16.0, Defendant's Contentiorisi- / dec/ans under penalty of perjury under the.laws ofthe State of
Personal Injury, should not be used uritil the defendant has
Califomia that ttie foregoing answers are tnje and correct.
had a reaspnable opportunity to conduct an investigation or
discovery of plaintiffs injuries and damages.
(e) Additional interrogatpries may be attached. (Date) (SIGNATURE)
Sec. 3. Instructions to the Answering Party Sec. 4. Definitions
(a) An answer or otiier appropriate response must be given to Words in BOLDFACE CAPITALS in these interrogatories are
each interrogatory checked by the asking party. defined as follows:
(b) As a general rule, within 30 days after you are served with (a) (Check one ofthe following):
these Interrogatories, you must serve your responses on the
asking party and serve copies of ypur responses on all other I I (1) INCJpENt indudes the circumstances and
parties to the.action who have appeared. See Code of Civil events sunounding the alleged accident, injuiy,
or other occurrence or breach of contract giving
Procedure sections 2030.260-2030.270 for details.
rise to this action or proceeding.
'Page 1 of 8
' Foftn Approved for Optional Use Code of Civil Procedure, §§
Judicial Council of California FORM I N T E R R O G A T O R I E S — G E N E R A L ,2030.010-2030.416, 2033.710
piSC-001 [Rev. Januaiy 1,2008) www.cpui1s.ca.g<3v
DISC-001
(2) I NCIDENT means (insert yoijr definition here or on a '1.0 Identity of Persphs Answering these Interrogatories
separate, attached sheet labeled 'Sec.:4(a)(2)''): I -< I 1.1 Statie the name, ADDRESS, telephone nUrriber, arid
Office ofthe State Fire MarshaPs adoption ofthe relationship to you pf each PERSON who prepared or
Automatic Fire Extinguishing Systems Certification assisted in the preparation oHhe responses to these
regulations, Califomia Code of Regulatibhs, title 19, interrogatories. (Do not identify anyone who simply typed
ChajDter 5.5 or reproduced the responses.)
2.0 General Background Information individual—
(b) YOU OR ANYONE ACTING ON YOUR BEHALF iricludes r I ;2.1 State:
ypLi, ypur agerits, your emplbyees, your insurance (a) ypur harrie;
cpmpanjes, their agents, their employees, your attomeys, (b) every name ,ydu have used in the jsast; and
your accountants, your irivestigators, and anyone elsje aictirig
on your behalf. (c) the dafiss you used each name.
I I 2.2 State the date arid place of your birth .
(c) PERSON includes a natural person, firm, association,
organization, partnership,, business, trust, liriiited liability r~~l 2.3 At ttie time of the INCIDENT, did you have a driver's
corfipany, corporation, or public entity. license"? If so state:
(d) DOCUMENT means a writing, as defined in Evidence Code (a) the state or othei^ issuing entity;
section 250, and includes the original or a copy of (b) the licerise nijrnber and type;
handwriting, typewriting, printing, phbtbstats,'photographs, (c) the date of issuance; arid
electronically stored inforrriatiori, and every other fneaiis pf (d) all restrictions.
recording uppri any tangible thing and fonn of communicating
I I 2.4 At the time bf the INCIDENT, did you have any pthef
or representatiori, including letters, words, pictures, sounds,
perrriit or license for the bperation of a mbtor vehicle? If so,
or symbols, or combinations of them.
state:
(e) HEALTH CARE PROVIDER includes ariy PERSON.referred
to in Code bf Civil Procedure section 667.7(e)(3). (a) the state or other issuing entity;
(f) ADDRESS means the street address, including the city, (b) the.liceiTise number and type;
state, and zip code. (c) the date of issuance; and
(d) all restrictions.
Sec. 5. Interrogatories
I I 2.5 State;
Ttie following interrogatories have been appi^pved by the Judicial
(a) your present residence ADDRESS;
Council under Code bf Civil Procedure section 2033.710:
(b) ypur residence ADDRESSES fpr the past five years;
CONTENt$ and
I .OIdentity of Persons Ansvyering These Interrogatories (c) the dates you liyed.at each ADDRESS.
2.6General Background Information—^Individual I I 2.6 State:
S.OGeneral Background Informatiori—Business Entity (a) the name, ADDRESS, and telephone iiuniber of your
4.6 Insurance present employer pr place of self-eriiployment; and
5.0/Rese/ved7
6.0Physical, Mental, or Emotional Injuries (b) the narne, ADDRESS, dates Of employment, job title,
7.0 Prbperty Damage and nature of work Ifor each employer or self-
8.0 Loss of Income or Earning Capacity employment you have had from five years before the
9.0Other Daniages INCIDENT until today..
10.0 Medical History I I 2.7 State:
11.0 Other Claims and Previous Claims
12,0 Investigation—Gerierai (a) the name and ADDRESS of each school or other
13.0 Investigation—Surveillance academic or vocational institution you have attended,
14,0 Statutory dr.Regulatory Violatioris beginning with high.school;
15.0 Denials and Special or Affirmative Defenses (b) the dates you attended;
16.0 Defendant's Contentions Personal Injury (c) the highest grade level you have completed; and
17.0F[esponses to Request for Admissions
(d) the degrees received.
^8.Q[Resenfed]
^9.0[Reserve^ 1 I 2.8 Have yoii ever been cbnvicted ofa felony? If so, for
20.OH0W the Incident Occurired—Motor Vehicle each conviction state:
25.0/Rese/ved/ (a) the city arid state where you were convicted;
30.0//?ese?vec(/ (b) the date of convictibh;
40.0/Rese/ved/
(c) the offense; and
ad.dContract
60.Q[Reserved] (d) the court and case number.
70.pUnlawful Detainer [See separate form D/SC-003/ I * 1 2.9 Can you speak English with ease? If not, vyhat
101 .OEconomic Litigation [See separate form DISC-004] language and djalect do you nprmally use?
200.0Employment Law [See separate tortn D/SC-002/ Family I M I 2,10 Can you. read aiid write English with ease? If riot,
Law [See separate fonn FL-145] what language arid dialect do you norrnally use?
piSC-001 [Rev. January 1.20Cei Page 2 of 8
FORM INTERROGATORIES—GENERAL
DISCTOOI
2.11 At the tirtie of the I NCIDENT were you acting as an I X I 3.4 Are you a joint venture? If so, state:
agent or emplpyee for any PERSON? If so, state: (a) the current joint venture harrie;
(a) the name, ADDRESS, and telephone .number of that (b) all bthei^ riameKused by the jojnt venture during the
PERSON: and past.lOyeareand the da^^^ eachifyas used;
(b) a descriptibri bf ypUr dutieis. (c) the name and ADDRESS of each joint venturer; arid
I 1 2.12 At the time of the INCIDENT did you or any other (d) the A D D R E S S of the principal place pf busiriess.
person have any physical, eitibtibhal, or mental .disability or
condition that maV have contributed tbthe occurrence of the I :M :\ 3.5 Are you an.uhihcbrporated assPciatipn? If so, state:;
INCIDENT? If so, for each perspli state; (a) the cun'ent unincdtpprated asspciatiori name;
(a) the name, ADDRESSi and telephone number; (b) all other names used by the unincorporated
(b) the nature of the disability brOThdition;and association during the past 10 yeare .and the. dates
(c) the manner in which the disability or condition eacSi was used; and
poritri.butecl to the pccurreripe of the INClbENT. (c) the ADDRESS bf the principal place of business.
I I 2.13 Within 24 hours before the INCIDENT.did you or any j K 1 3.6 Have you done business under a fictitious nam^^ duririg
pei"sori involved in the INCIDENT use 'br take any pf the the past 10 years'? If so, for each fictitious name state:
fgljbwing substarires: alra marijuana, or
other drug or medication of any kind (prescription or not)? If (a) the name;
;so, for each person state: (b) the daites each was used;
(a) the name, ADDRESS, and telephone number; (c) the state and county of each fictitious nanie filing; and
(b) the nature or description of each substance; (d) the ADDRESS ofthe prindpal pla(::e; of business.
(c) the quaritjty of each substahre iised or taken; I n I 3,7 ywthiri the past five years has any public entity
(d) the date and time of day when each substaiice was registered or licensed your business? If so, for each licerise
used oi^ taken; or registration:
(e) the ADDRESS where each substance was used or
(a) identify the license bi" registration;
takeo-
ff) the name, ADDRESS, arid telephoneriurriber,bf each (b) state the riame of the publjc entity; and
person who vyas jDreseht Wheri each substance was (c) state the dates bf issuance arid expiration.
used or taken; and 4.0 Insurance
(g) the name, ADDRESS, and telephone riiirtiber of any I I 4.1 At the time of the INCIDENT, was there in effect any
HEALTH CARE PFtOVIDER who prescribed or policy of irisui'arice through which you yvere or might be
furnjshed the substance and the condition for which it insured in any manner (for example, primary, pro-rata, or
was prescribed or furnished. excess liability coverage br riiedical expense coverage) fbr
3.0 General Background Infonnation—Business Entity the darriages, daims, br actioiis that have ariseri Put of the
INCIDENT? If .so, for each policy state;
I « I 3.1 Are you a corporiatibn? If so, state:
(a) the name stated in the curi'erit articles of incorporation; (a) the kind of coverage;
(b) all pther names used by ttie corporation during the past (b) the riame arid ADDRESS ofthe insurarice company;
10 years and the dates each was used; (c) the nanie, ADDRESS, and telephone number of each
(c) the date and place of incorporation; named insured;
(d) the ADDRESS of the prindpal place pf business; and (d) the policy riunriber;
(e) whether you are qualified tb dp biisiriess in Califoririia,
(e) the limits of coverage for each type of coverage
I « I 3.2 Are you a partnei^ship? If so, state:
contained in the pblicy;
(a) the currerit partnership riame;
(f) whether any reservation of rights pr controversy or
(b) all other names used by the partnership during the past
coverage dispute exists betyveen ypu and the
10 years and the dates each was used;
insurance company; and
(c) whether you are a limited partnership and, if so, iirider
(g) the name, ADDRESS, and telephone number of the
the laws of what jurisdiction;
custodian of the pblicy.
(d) the name and ADDRESS of each general partner; and
I I 4,2 Are you self-insured urider any statute for the
(e) the ADDRESS of the principal, place bf business, damages, daims, or actions that have arisen out of the
I * I 3.3 Are ybu a limited liability cphipariy? If so, state; INCIDENT? if so, specify the statute.
(a) the nanie stated in the current articles of organization; 5.0 [Reserved]
(b) all other names used by the cornpany iJuririg tiie past 6.0 Physical, Mental, or Ernptipnal Injuries
10 years aind tlie date each was used;
1 I 6.1 Do you attribute any physical, mental, or ernotional
(c) the date and place bf fjlihg of the articles of injuries to the INCIDENT? (If ydiir answer is "no, " do r7o(
organization; ariswerinterfqgatqries 6.2 thrpugti 6.7).
(d) the ADDRESS bf the principal place bf buisiness; and
1 I 6.2 Identify each injury you attribute to the INCIDENT and
(e) vyhefher you are qualified tp do business in Califpmia. the area of your body affected.
DISC-001 [Rev. Januaiy 1. 2008]
FORM I N T E R R O G A T O R I E S — G E N E R A L Page 3 of 8
DISC-001
J 6-3 Do you still have any complaints that you attribute to the (c) state the amount of .damage yPu are dairnirig for
INCIDENT? If so, for each cpmpiaint .state: each item bf prpperty and hpyv the ampuht was
calculated; and
(a) a descjiptipn;
(b) whether the complaint is subsiding, remaining the (d) if the property was spld, state the riiarne, ApbRESS,
same, or becoming worse; and ariii te|ephpne number of the seller, the date of sale,
and the sale price.
(c) the frequency and duration.
2] 6.4. Did ybu receive any cpriisultafion or examinatipri (except I I 7.2 Has a written estimate or evaluation been made foi" ariy
from expert yi/itnesses cpyered ,by Code of CiviJ Procedure item of property referred to in your answer to the preceding
sedioris 20i*.21(>^^ or treatment from a HEALTH interrbgatory? If so, for each estiniate or eyaluatipn state:,
CARE PROVIDER for any injury you attribute to the (a) the name, ADDRESS, and telephone humbel' Pf the
INCIDENT? if so, for each HEALTH CARE PROVIDER PERSON yvhb prepared it and the date prepared;
state:
(b) the name, ADDRESS, and telephone number of each
(a) the h^ame, ADDRESS, and teiephone number;
PERSON who has a pppy of it; and
(b) the type of cprisiiltatipri, examination, or treatment
(c) the amount of damage stated.
provided;
(c) the dates you received consultation, examination, or I I 7.3 Has any iterfi bf.pfbperty referred to in your ansvver to
treatment; and intenrogatory 7.1 been repaired"? If so, for each iterii statie:
(d) the charges to date. (a) the date repaired;
^ 6.5 Have ybu taken any medicatibn, prescribed or not, as a (b) a description of the repair;
result pf injuries that ypu attribute tp the INCIDENT? if so,
(c) the repair cost;
for each medication state:
(d) the name, ADDRESS, arid telephone riufriber pf the
(a) the iiame;
PERSON vyhb repaired it;
(b) the PERSON who prescribed Pi" fumished it;
(e) the name, ADDRESS, arid telephone number bf the
(c) the date it yvas prescribed, pr furnished; PERSON who P^id for the repair
(d) the dates you began and stopped taking it; and
8.0 Loss of Incoitie or Earning Capacity
(e) the cPst tp date.
I I 8,1 Do you attribute any loss of income or earning capacity
6,6. Are there any other medical services necessitated
by the inj
Preview
1 ROB BONTA 2 Attorney General of Califomia RUSSELL B. HiLDRETH FiIEB/£1^00RS!ED Supervising Deputy Attomey General 3 ANDREA M . KENDRICK State Bar No. 225688 SEP 2 8 2022 COURTNEY S. COVINGTON, State Bar No. 259723 4 Deputy Attomeys General By:. E. Macdnnalri 13001 Street, Suite 125 Deputy Clerk 5 P.O. Box 944255 Sacramento, CA 94244-2550 6 Telephone: (916)210-7821 Fax: (916)327-2319 7 E-mail: Ajndrea.Kendrick@doj.ca.gov 8 Attorneys for Defendants Exempt from Filing Fees Pursuant to Gov. Code § 6103 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SACRAMENTO 11 12 13 FIRE GUARD CORPORATION; Case No. 34-2019-00249221-CU-CR-GDS RAHMAN BRIAN SHAHANGIAN, an 14 individual; and CALIFORNIA FIRE DECLARATION OF ANDREA M. PROTECTION COALITION, a California KENDRICK IN SUPPORT OF 15 Corporation; and JUAN CARLOS DEL DEFENDANTS' MOTION (A) TO TORO TREJO, an individual, COMPEL PLAINTIFFS FIRE GUARD 16 CORPORATION, BAHMAN BRIAN Plaintiffs, SHAHANGIAN, AND JUAN CARLOS DEL 17 TORO TREJO TO PROVIDE RESPONSES V. TO (1) SPECIAL INTERROGATORIES 18 (SET ONE), (2) FORM INTERROGATORIES (SET ONE); AND (3) 19 CALIFORNIA DEPARTMENT OF REQUESTS FOR PRODUCTION OF FORESTRY AND FIRE PROTECTION; DOCUMENTS (SET ONE); AND (B) FOR 20 CALIFORNIA OFFICE OF THE STATE AN ORDER DEEMING ADMITTED THE FIRE MARSHAL; MIKE RICHWINE, in REQUESTS FOR ADMISSION (SET ONE) 21 his official capacity as State Fire Marshal; JEFFERY SCHWARTZ, in his official Date: October 27, 2022 22 capacity as Deputy State Fire Marshal; and Time: 1:30 p.m. DOES 1 through 10, inclusive, Dept.: 53 23 Trial Date: December 18, 2023 Defendants. Action Filed: January 25, 2019 24 Reservation No.: 2663593 25 26 27 28 1 Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221) 1 I, Andrea M. Kendrick, declare: 2 1. I am an attomey licensed to practice in all of the courts in the State of Califomia and 3 a Deputy Attomey General in the Califomia Attomey General's Office, counsel of record for 4 defendants in this action. I have personal knowledge of all the matters set forth herein and, if 5 called as a witness, I could and would competently testify thereto. 6 2. Attached as Exhibit A is a tme and correct copy of the Special Interrogatories (Set 7 One), Form Interrogatories (Set One), Request for Producdon of Documents (Set One), and 8 Requests for Admission (Set One), that defendant Office of the State Fire Marshal (OSFM) 9 served on plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del 10 Toro Trejo (collectively, Fire Guard and the Individual Plaindffs), on August 28. 2020. 11 3. Attached as Exhibit B are tme and correct copies of emails between counsel for Fire 12 Guard and the Individual Plaintiffs and me in which Fire Guard and the Individual Plaintiffs 13 requested an extension to November 2, 2020, to respond to the discovery requests, and an email 14 from me granting the request. 15 4. Fire Guard and the Individual Plaintiffs did not object to or respond to any of the 16 discovery requests nor did they seek or receive another extension of time before or on November 17 2, 2020, to respond. 18 5. In December 2020, the parties agreed on a stay of discovery until the end of January 19 29, 2021, which was ultimately extended to the last part of 2021. 20 6. During the stay, counsel for Fire Guard and the Individual Plaintiffs requested 21 confirmation that his client could respond to the outstanding discovery after the stay. Attached as 22 Exhibit C is a tme and correct copy of an email from me to counsel for Fire Guard and the 23 Individual Plaindffs confirming that when the stay on discovery ends, the OSFM reserved its 24 right to seek appropriate relief regarding Fire Guard and the Individual Plaintiffs' failure to 25 respond to the outstanding discovery on or before the November 2, 2020, due date. 26 7. Attached as Exhibit D is a tme and correct copy of a letter from me to counsel for 27 Fire Guard and the Individual Plaintiffs, dated January 11, 2022, in which the OSFM requested 28 2 Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221) 1 that Fire Guard and the Individual Plaintiffs respond to the OSFM's discovery requests on or 2 before Febmary 10, 2022, and that if they did not the OSFM would seek relief from the Court. 3 8. Counsel for Fire Guard and the Individual Plaintiffs did not respond to the letter 4 attached as Exhibit D. 5 9. Attached as Exhibit E is a tme and correct copy of an email from me to counsel for 6 the Individual Plaintiffs dated March 8, 2022, asking counsel for Fire Guard and the Individual 7 Plaintiffs whether they provided a response to the outstanding discovery requests. 8 10. As of the date of the filing of this motion. Fire Guard and the Individual Plaintiffs 9 have not responded to the OSFM's discovery requests or to my January 11, 2022 letter or my 10 March 8, 2022 email regarding responding to discovery. 11 I declare under penalty of perjury under the laws of the State of Califomia that the 12 foregoing is tme and correct. 13 Executed on September 28, 2022, in Gait, Califomia. 14 Andrea M. Kendrick 15 16 17 SA2019300028 36465797.docx 18 19 20 21 22 23 24 25 26 27 28 Declaradon of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221) 1 EXHIBIT LIST 2 3 A Special Interrogatories (Set One) Form Interrogatories (Set One) 4 Request for Production of Documents (Set One) 5 Request for Admission 6 Served by Defendant Office of the State Fire Marshal (OSFM) on plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del Toro Trejo 7 (collectively, Fire Guard and the Individual Plaintiffs), on August 28, 2020 8 B Email communications between Timothy Kassouni, counsel for Fire Guard and 9 the Individual Plaintiffs, and Andrea M. Kendrick, counsel for defendants 10 C Email communication between Andrea M. Kendrick, coimsel for defendants, to 11 Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs 12 D Letter dated January 11, 2022, from Andrea M. Kendrick, counsel for defendants, 13 to Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs 14 E Email dated March 8, 2022, from Andrea M. Kendrick, counsel for defendants, to 15 Timothy Kassouni, counsel for Fire Guard and the Individual Plaintiffs 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Andrea M. Kendrick In Support of Defendants' Motion to Compel (34-2019-00249221) Exhibit A 1 XAyiERBECERRA AttOiTiey Gehei'ail of Galiforhia 2 TkAcY L. WJNSOR Supervising Deputy Attomey General 3 ANDREA M . KENDRICK, State Bar No. 225688 RUSSELL;B. HiLDRETH, State Bar No. 166167 4 Deputy Attorney Genieral State Bar No. 225688 5 13001 Street, Suite 125 P.O. Box 944255 6 Sacramento, CA 94244-2550 Telephone: (916)210-7821 .7 Fax: (916) 327-2319 E-mail:; Andrea.K^ 8 Attomeys for Deferidgnts 9 SUPERIOR COURT OF THE STATE OF GALIFORNIA 10 COUNTY OF SACRAMENTO II 12 13 FIRE GUARD CORPORATION; Case No, 34-2019-00249221 BAHMAN BRIAN SHAHANiGIAN, an 14 individual; CALIFORNIA FTOE SPECIAL INTERROGATORIES t o PROTECTION COALITiON, a California PLAINTIFFS FIRE GUARD 15 Corporation; arid JUAN CARLOS DEL CORPORATION, BAHMAN BRIAN TORO TREJO, an individual, SHAHANGIAN, and JUAJS CARLOS 16 DEL TORO TREJO (SET ONE) Plalntififs, 17 18 19 CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION; 20 CALIFORNIA OFFICE OF THE STATE FIRE MARSHAL; MIKE RICHWINE, in 21 his ofRcial capacity as State Fire Marshall; JEFFREY SCHWARTZ, in his official 22 capacity as Deputy State Fire Marshal; arid D O E S 1 through 10, inclusive, 23 Defendants;, 24 25 PROPOUNDING PARTY: Defendant pfifice of the State Fire, Marshal 26 RESPONDING PARTY: Plaintiffs Fire Guard Gpiporation, Bahnian Brian Shahangian, and 27 Juan C!arjos Del Toro Trejo 28 SET NO. ONE (1) Special Interrogatories to Plaintiffs Fire Guard Corp-^ Shahangian, and Trejo (One) (34-2019.-00249221) 1 Pursuant to Godei of Civil Procedure section 2030.010 et seq., yiDu or ybiif legal 2 iepresehtatives are required to resppnd to the follpvving special interrogatories, separately and iri :3 Y^ting xinder oath, wHthih 30 d 4 SPECIAL INTERROGATORIES 5 iSPECIAL iNTEimbGATORY NO. 1; 6 Identify ijy hahie,title;,and address, all OFFICERS, (as used heirein, the terms "OFFICER" 7 and "OFFICER(s)", shall mean any indiyidual person holding a position of executive manageriient '8 within a corporatioii, incMdlng biit not limited to the pfesideiit, vice-president, chief executive 9 officer, chieffinancialofficer, and/or secretary) and directors of FIRE GUARD (as used herein, 10 the term "FIRE GU ARD"'refers, to plaintiff Fire Guard Corporation) froiii January 1, 2013, 'to, tiie 11 present: 12 iSPECiAL INTERROGATORY NO. 2: 13 State whether or npt each person identified in YOUR respprise tp Special intep-pgatoiy 14 No. 1 recdved any DOGUMENTS (as used, herein, the tehns "DOCUMENT' or 15 "PpCUMENTS" shall mean any and all written, printed, recprded, graphic, or photographic 16 materials of any kind or description, as defined in Eyidence Code sectipn 250, including without 17 limitation electronic and hardcopy dpciiments) from the OSFM (as used herein, "OSFM" refers to 18 defendant Office ofthe State Fire Marshal) regarding the REGULATIONS (as used herein, the 19 terra "REGULATIONS," mearis the Aiitomatic Fire Extingtaishing Systems Certification 20 regulations, Califoiiiia Code pf Reguiations, title 19, Chapter 5.5.). 21 SPECIAL INTERROGATORY NO. 3: 22 I f ariy person YOU identified in YOUR response tp Special Interrogatory No. 1, received 23 any DOCUMENT from the OSFM regarding the REGULATIONS, IDENTIFY EACH 24 DOCXJMENT (as used hei-ein, the term "IDENTIFY EACH DOCUMENT,", means to describe 25 the DOCUMENT with sufficient specificity to allow the OSFM to know what and where the 26 DOCUMENT is, iticluding: (1) the date of the DOCUMENT, (2) the author(s) of the, 27 28 2 Special Iriterrogatorieis to Plaintiffs Fire Guard Corp., Shahangian, and Trejo (One) '(34-2019-00249221) 1 POGUMENT, if known; (3) the type bf DOCUMENT (e.g., letter, report^ notice, etc.); (4) the .2 name of the person who received the pOGUMENT); and (5) th_e custpdian of the pOGUMENt) .3 that person .received. 4 SPECIAL INTERROGATORY NO. 4; 5 .State whether orriotFIRE GUARD received any DOCUMENTS from the OSFM 6 regarding the REGULATIONS. 7 SPECLiL INTERROGATORY NO. 5: 8 I f FIRE GUARD ireceived any DOCUMENTS from tiie OSFM regarding the 9 REGULATIONS, IDENTIFY EACH DOCUMENT tiiat FIRE GUARD received, 10 SPECIAL INTERROGATORY No. 6: 11 State the mahrier in which FIRE GUARD aiid each of its OFFICERS and directprs 12 became aware of the final adopted REGULATIONS. 13 SPECIAL INTERROGATORY NO. 7; 14 State the names and addresses Pf all employees Pf FIRE GUARD from January 1,2013, to 15 the present. 16 SPECIALINTERROGATORY NO. 8; i7 State whether or hot plaintiff Bahman Brian Shahangian received any pOCUMENTS 18 from the OSFM regarding the REGULATIONS. 19 SPECIAL INTERROGATORY NO. 9: 20 I f plaintiff Bahman Brian Shahangian received any DOCUMENTS from tiie OSFM 21 regarding tiie REGULATIONS, IDENTIFY EACH DOCUMENT that Mr. Shahangian received. 22 SPECIAL INTERROGATORY NO. 10: 23 State vvhether or not plaintiff Juan Carlos Del Toro Trejo received any DOCUMENTS 24 from tiie OSFM regarding tiie REGULATIONS. 25 SPECIAL INTERROGATORY NO. 11; 26 If plaintiff Juan Carlos Del Toro Trejo received any DOCUMENTS from the OSFM 27 regarding the REGULATIONS, IDENTIFY EACH DOCUMENT that Mr. Trejo received. 28 3 Special Interrogatories to Plaintiffs Fire Guard Co^p., Shahangian, and Trejo (One) (34-2019-00249221) 1 SPECIAL INTERROGATORY NO. 12: 2 :State all facts that support YOUR cpntentipn in Paragraph 26 of the jFIRST AJVIENpEp 3 COMPLAINT (as used herein, the.teriri "FIRST AMENDED COMPLAINT" means the First -4 Ameiaded Complairit for Declaratpiy # d Injimcti^ Relief, filed by plaintiffs Fire Guard 5 CPrpPfatipn, Bahman Briain Shahaiigiati, CalifoiTiia Fire Protection Coalition, and Jiian Garlps ?6 Del Toro Trejo, in Sacrarnento County Superior Court, case number 34-2019-0024922 Pf 7 iabout May 2, 2019) that in the-case herein, the "licensirig system requires extetisiye testing or 8 educatipn pitiy tangentially related to an applicant's fitness to practice his or her chosen 9 . occupation." 10 SPECIAL INTERROGATORY NO. 13: 11 Identify each witness Ayith knowledge that siipipoits YOUR Cpriteritibn in Paragraph 26 of 12 the FIRST A M E N P E D COMPLAINT that iri the case herein, the "Ucensing system requires 13 extensive testing br education only tangentially related tb an applicant's fitness to practice his or 14 her chosen occupation." 15 SPECIAL INTERROGATORY NO. 14; 16 IDENTIFY EACH DOCUMENT which supports YOUR contentipri iri.Paragraph 26 pf 17 the FIRST AMENDED COMPLAINT tiiat m the case herein, the "licensing system requires 18 extensive testing or educatibn only tarigentialiy related to an applicant'sfitnessto practice his or 19 her chosen bcciipatioh." 20 SPECIAL INTERROGATORY NO. 15: 21 State ail factstiiat.supportYOUR contention in Paragraph 26 ofthe FIRST AMENDEP 22 COMPLAINT that in the case herein, the "licensing systein . . . . has a tenuptis cbririectibn tb the 23 protection of the public'' 24 SPECIAL INTERROGATORY NO. 16: 25 Identify by name, title, and address, each witoess with knowledge that suppprts YOUR 26 coiitentipn in Paragraph 26 oftiieFIRST AMENDED COMPLAINT tiiat intiiecase herein, tiie 27 "licensing system.,. has a tenugiis connectipn to the protection of the piiblic." 28 4 Special Interrogatories to Plaintiffs Fire Guard Corp., Shahangian. and Trejo (One) (34-2019-00249221) 1 SPECIAL INTERROGATORY NO. 17: 2 IDENTIFY EACH DOCUMENT which suppprts YOUR cpntentipii in Paragraph 26 of 3 the FIR5T AMENDED COMPLAINT tiiat iri the case herein, the "hcerisirig systeiri... has a 4, teritioiis cbnnectibri to the protection of the public/' 5 SPECIAL INTERROGATORY NO. 18; .6 State all facts that support YOUR, contentipn in Paragraph 27 of Jhe FIRST AMENDED 7 COMPLAINT that in tiie case herein, "the burdeii of licensure reqiiirerrieiits is greatly out of 8 'pfbpbrtion with alleged public beriefits cfeatied by those requirements.'' 9 SPECIAL INTERROGATORY NO. 19: :10 Identify by name, title, and address, each vvitness with knowledge that supports YOUR 11 cpntentipn in Paragraph 27 pf tiie FIRST AMENDED COMPL AINT that in tiie case herein, "tiie 12 burden of licensure requirements is greatly out of propprtion with alleged public benefits created 13 by thpse requirements." 14 SPECIAL INTERROGATORY NO. 20: ;i5 IDENTIFY EACH POCUMENT which supports YOUR contention in Paragraph 2? of 16 the FIRST AMENDED COMPLAINT that m tiie case herein, "tiie burden pf licensure 17 reqiiireriients is grieatly put bf propbrtibri with alleged public beriefits created by those 18 requirements." 19 SPECIAL INTERROGATORY NO. 21: 20 State all facts that support YOUR cbritention m Paragraph 50 bf the FIRST AMENDED 2i COMPLAINT that"' [t]he regulatory scheme impairs the contiactual rights of existing C-16 22 license holders, who have executed confracts for cbnunercial sprinkler work without actual notice 23 of the regulatory scheriie or ifs grandfathering timeframes;" 24 SPECIAL INTERROGATORY NO. 22: 25 Identify by name, title, and address, each witaess with knowledge that supports YOUR 26 cpnteiitipn in Paragraph 50 oftiieFIRST AMENDED COMPLAINT tiiat '" [t]he regulatory 27 scheme impairs the contractual rights of existing C-16 license holders, who have executed 28 5 Special Interrogatories to Plaintiffs Fire Guard Corp., Shahiangian, and Trejo (One) (34-2019-00249221) 1 contracts for eonimercial sprinkler wprjk withptit actualripticebf the reguiatbry schexrie or its % grandfatheririg tiniefrariles." 3 SPECIAL INTERROGATORY NO. 23: 4 IDENTIFY EACH POCUMENt whict supports in YOUR contention in Paragraph 50 of -5 tiie FIRST AMENDED COMPLAINTtiiat"'it]he regulatory scheme impairs the cbntiactiial 6 rights bf existing C-l 6 licerise hblders, who have executed confracts for conimercial sprinkler 7 work vwthbut actual notice ofthe regulatory scherne or its grandfathering timefiumes." 8 SPECIAL INTERROGATORY NO. 24; 9 Identify by the names of tiie contracting piarties and the date(s) bf execution, each 10 cbritiactuai agreetrierit Which YOU contend in paragraph 51 pf the FIRST AMENpED 11 COMPLAINT, is "unpaired by the regulatory schenie;" 12 13 Dated: August 28, 2020 Respectfully Submitted, 14 XAVIER BECERRA Attpmey Cierieral Pf Califomia 15 TRACY L. WINSOR 16 Supervising Deprify Attorriey General 17 18 ANDREA M. KENDRICK 19 Deputy Attomey General Attorneys for Defendants 20 21 SA20.19300028 3432408 l.docx 22 23 24 25 26 27 28 Special IriteiTOgatories to Piairitiffs Fire Guard Corp., Shahangian, and Trejo (One) (3472019-00249221) DECLARATION OF SERVICE BY E-MAIL and U.S. MAIL Case Name: Fire Guard Gprporatipn, et al. v. California D Fire Prbtectidri, et al. Case No.: I^acrariieritb County Superior Gourt Case No. 34^2Cil9-6624922i 1 deciafe: I arn enipibyed.in the Office of the Attpmey •Qenefa^ which is the office pf a meri^^^ the 'California State.Bar; at which meniber's direction this service is made, fam I8.yeai-s of age or bld^r. and nbt'a party t^ this matter; I. am,familiaivwith the bus^ Office of the Attorriey General for cbllectibri arid.pi'bcessirig^b fbf irriailmg with the United States P.pstal Service.- in accordance with that- practice, cprrespondericc;placed iri the iritemal mail epiiectipri.sy^^^ withlhe UnitbdiStates Postal Service with postage thereon fully prepaid that sa'me'day m the ordinary course of husiries's. On August 28. 2020.1 served the attached Special Interrogatories to Plaintiffs Fire Guard Corppratipii, Bahihan Brian Shahangiari, |in^ juari Carlos Del Tprp Trejo (Set ,Oiie) by placing a true copy tiierepf enclosed in a sealed envelope, in the interilal niail systerri bf the ^Office of the Attorney Geneml, addressed as follows: Tirnpthy V, .Kasspurii Attorney at Law Kassouni Law 621 Capitol Mall, Suite-2p25 Sacfamento, GA '^5814. timothv(fl),kassounilaw.com In addition, on August 28. 2020.1 served the attached Special Interrogatories to iPlairitiffs Fire Guard Corporation, Bahniian Brian Shahangian, and Juan Carlos Del Tpro Trejo (Set One) by trarisrnittirig a triie copy via electrbrii tb: Margaret Esquifbz, Esq. 49i4 Balboa Boulevard, #500 Encinp. CA 91316-3402 esc]uiroz(a),piri.me I declare under penalty of perjury under the laws of the State Of Califprnia and the United States of America the foregoing is true and correct and that this declaratiori was executed bn August 28, 2020, at Sacrarrieritp, California. Ann-Marie.Doersch Declarant \-y ^igriatufe SA2ai')]ooo:3 34361 lOO.docx DISC-001 ATTORNEY OR PW^T/ wmnOU^ Sfafe earnumter, sndaddressj; Andrea M; Kendrick (SBN 22568.8) Califdiriia Department bf Justice 1300 1 Street. Suite 125 Sacramento, GA 951514 TELEPHONENO.: (916)210-7821 FAX NO. pptidnal): (916) 327,-2319 E-MAIL ADDRESS (Optional): Andrea.Kendrick@dbj.ca.gov ATTORNEY FOR (wa/ne): Defendants California Department of Forestry and Fire Protection, et al. SUPERIOR couRTiOF dALiFiDRNiA. couNTV OF Sacrame^^ SHORT TITLE OF CASE: Fire Guard Corporation, et al. v. Califomia Departrnerit of Forestry and Fire Protection, et al. FORM INTERROGATORIES—GENERAL CASE NUMBER; 34^2019^00249221 Asking Party: Defendant Office of the State Fire Marshal A n s w e r i n g Party:, Plaintiffe Fire Guard Corp., Mr. SHahangiah, and Mr. Trejo Set No.: One Sec. 1. instructions to All Parties Each ansvyer must be as complete and.straightforward as (aj jnterrpgatorjes are written questions prepared by a party to an the information reasonably available to ygli, includirig the. action that are sent to any other party in the actipn to be itiforrriatiori possessed by your attomeys or agerits, permits. ansvyered under oath. The interrogatories bejow are forrn If an interrogatory cannot be answered completely, answer it ihterrogatpries approved fpr use in ciyi| cases. to the extent possible. (b) For time limitations, requirernents for sen/ice ph other parties, (d) |f you do not have enough personal knowledge to fully and other details, see Code of Cjvil Procedure sections answer an interrogatory, say so, but make a reasonable and 2030.01 (>^2b30.410 and the cases construing those sections. good faith effort to get the information by asking other (c) These form interrogatories do not change existing law persons or organizations, unless the infpntiatidri is equally relating to interrogatories nor do they affect an answering available tp the asking party. party's right to assert any privilege or niake any objection^ (e) Whenever an interrogatory rriay be ansyyered by referring to Sec. 2. Instructions to the Asking Party a dpcurnent, the dociiment may be attached as an exhibit to (a) These interrogatories are designed for optional use by parties the response and referred to in the response. If the. in unlimited civil cases where the amount demarided exceeds document has more than.one page, refer to the jsage and $25,000. Separate interrogatories, Form Interrogatories— sectibri where the arisyyer to the interrogatory can be fpund. Lirnited Civil Cases.(Economic Litigation) (form blSC-004), Whenever an address arid telephone number for the same (f) which have no subparts, are designed for use in limited civil person are requested in more than one interrogatory, you cases where the amount demanded is $25,000 or less; are required to furnish them in answering only the first however, those interrogatories may also be used in unlimited interrogatory asking for that informatibri, civil cases. (b) Check the box next to each interrogatory that you want the (g) If you are asserting a privilege or making an objection to an ariswerihg party to answer. Use care in choosing those interrogatory, you must specifically assert the privilege bi" interrogatories that are appiicabie to the case. state the objection iri your written resporise. (c) You may insert your own definition of INCIDENT in Section 4, (h) Your answers to these interrogatories muist be verified, but only where the action arises from a ciourse of conduct or a dated, and signed. You may wish to use the following form series of events occurring over a period pf time, at the end of your aniswers: (d) t h e inten'ogatories in section 16.0, Defendant's Contentiorisi- / dec/ans under penalty of perjury under the.laws ofthe State of Personal Injury, should not be used uritil the defendant has Califomia that ttie foregoing answers are tnje and correct. had a reaspnable opportunity to conduct an investigation or discovery of plaintiffs injuries and damages. (e) Additional interrogatpries may be attached. (Date) (SIGNATURE) Sec. 3. Instructions to the Answering Party Sec. 4. Definitions (a) An answer or otiier appropriate response must be given to Words in BOLDFACE CAPITALS in these interrogatories are each interrogatory checked by the asking party. defined as follows: (b) As a general rule, within 30 days after you are served with (a) (Check one ofthe following): these Interrogatories, you must serve your responses on the asking party and serve copies of ypur responses on all other I I (1) INCJpENt indudes the circumstances and parties to the.action who have appeared. See Code of Civil events sunounding the alleged accident, injuiy, or other occurrence or breach of contract giving Procedure sections 2030.260-2030.270 for details. rise to this action or proceeding. 'Page 1 of 8 ' Foftn Approved for Optional Use Code of Civil Procedure, §§ Judicial Council of California FORM I N T E R R O G A T O R I E S — G E N E R A L ,2030.010-2030.416, 2033.710 piSC-001 [Rev. Januaiy 1,2008) www.cpui1s.ca.g<3v DISC-001 (2) I NCIDENT means (insert yoijr definition here or on a '1.0 Identity of Persphs Answering these Interrogatories separate, attached sheet labeled 'Sec.:4(a)(2)''): I -< I 1.1 Statie the name, ADDRESS, telephone nUrriber, arid Office ofthe State Fire MarshaPs adoption ofthe relationship to you pf each PERSON who prepared or Automatic Fire Extinguishing Systems Certification assisted in the preparation oHhe responses to these regulations, Califomia Code of Regulatibhs, title 19, interrogatories. (Do not identify anyone who simply typed ChajDter 5.5 or reproduced the responses.) 2.0 General Background Information individual— (b) YOU OR ANYONE ACTING ON YOUR BEHALF iricludes r I ;2.1 State: ypLi, ypur agerits, your emplbyees, your insurance (a) ypur harrie; cpmpanjes, their agents, their employees, your attomeys, (b) every name ,ydu have used in the jsast; and your accountants, your irivestigators, and anyone elsje aictirig on your behalf. (c) the dafiss you used each name. I I 2.2 State the date arid place of your birth . (c) PERSON includes a natural person, firm, association, organization, partnership,, business, trust, liriiited liability r~~l 2.3 At ttie time of the INCIDENT, did you have a driver's corfipany, corporation, or public entity. license"? If so state: (d) DOCUMENT means a writing, as defined in Evidence Code (a) the state or othei^ issuing entity; section 250, and includes the original or a copy of (b) the licerise nijrnber and type; handwriting, typewriting, printing, phbtbstats,'photographs, (c) the date of issuance; arid electronically stored inforrriatiori, and every other fneaiis pf (d) all restrictions. recording uppri any tangible thing and fonn of communicating I I 2.4 At the time bf the INCIDENT, did you have any pthef or representatiori, including letters, words, pictures, sounds, perrriit or license for the bperation of a mbtor vehicle? If so, or symbols, or combinations of them. state: (e) HEALTH CARE PROVIDER includes ariy PERSON.referred to in Code bf Civil Procedure section 667.7(e)(3). (a) the state or other issuing entity; (f) ADDRESS means the street address, including the city, (b) the.liceiTise number and type; state, and zip code. (c) the date of issuance; and (d) all restrictions. Sec. 5. Interrogatories I I 2.5 State; Ttie following interrogatories have been appi^pved by the Judicial (a) your present residence ADDRESS; Council under Code bf Civil Procedure section 2033.710: (b) ypur residence ADDRESSES fpr the past five years; CONTENt$ and I .OIdentity of Persons Ansvyering These Interrogatories (c) the dates you liyed.at each ADDRESS. 2.6General Background Information—^Individual I I 2.6 State: S.OGeneral Background Informatiori—Business Entity (a) the name, ADDRESS, and telephone iiuniber of your 4.6 Insurance present employer pr place of self-eriiployment; and 5.0/Rese/ved7 6.0Physical, Mental, or Emotional Injuries (b) the narne, ADDRESS, dates Of employment, job title, 7.0 Prbperty Damage and nature of work Ifor each employer or self- 8.0 Loss of Income or Earning Capacity employment you have had from five years before the 9.0Other Daniages INCIDENT until today.. 10.0 Medical History I I 2.7 State: 11.0 Other Claims and Previous Claims 12,0 Investigation—Gerierai (a) the name and ADDRESS of each school or other 13.0 Investigation—Surveillance academic or vocational institution you have attended, 14,0 Statutory dr.Regulatory Violatioris beginning with high.school; 15.0 Denials and Special or Affirmative Defenses (b) the dates you attended; 16.0 Defendant's Contentions Personal Injury (c) the highest grade level you have completed; and 17.0F[esponses to Request for Admissions (d) the degrees received. ^8.Q[Resenfed] ^9.0[Reserve^ 1 I 2.8 Have yoii ever been cbnvicted ofa felony? If so, for 20.OH0W the Incident Occurired—Motor Vehicle each conviction state: 25.0/Rese/ved/ (a) the city arid state where you were convicted; 30.0//?ese?vec(/ (b) the date of convictibh; 40.0/Rese/ved/ (c) the offense; and ad.dContract 60.Q[Reserved] (d) the court and case number. 70.pUnlawful Detainer [See separate form D/SC-003/ I * 1 2.9 Can you speak English with ease? If not, vyhat 101 .OEconomic Litigation [See separate form DISC-004] language and djalect do you nprmally use? 200.0Employment Law [See separate tortn D/SC-002/ Family I M I 2,10 Can you. read aiid write English with ease? If riot, Law [See separate fonn FL-145] what language arid dialect do you norrnally use? piSC-001 [Rev. January 1.20Cei Page 2 of 8 FORM INTERROGATORIES—GENERAL DISCTOOI 2.11 At the tirtie of the I NCIDENT were you acting as an I X I 3.4 Are you a joint venture? If so, state: agent or emplpyee for any PERSON? If so, state: (a) the current joint venture harrie; (a) the name, ADDRESS, and telephone .number of that (b) all bthei^ riameKused by the jojnt venture during the PERSON: and past.lOyeareand the da^^^ eachifyas used; (b) a descriptibri bf ypUr dutieis. (c) the name and ADDRESS of each joint venturer; arid I 1 2.12 At the time of the INCIDENT did you or any other (d) the A D D R E S S of the principal place pf busiriess. person have any physical, eitibtibhal, or mental .disability or condition that maV have contributed tbthe occurrence of the I :M :\ 3.5 Are you an.uhihcbrporated assPciatipn? If so, state:; INCIDENT? If so, for each perspli state; (a) the cun'ent unincdtpprated asspciatiori name; (a) the name, ADDRESSi and telephone number; (b) all other names used by the unincorporated (b) the nature of the disability brOThdition;and association during the past 10 yeare .and the. dates (c) the manner in which the disability or condition eacSi was used; and poritri.butecl to the pccurreripe of the INClbENT. (c) the ADDRESS bf the principal place of business. I I 2.13 Within 24 hours before the INCIDENT.did you or any j K 1 3.6 Have you done business under a fictitious nam^^ duririg pei"sori involved in the INCIDENT use 'br take any pf the the past 10 years'? If so, for each fictitious name state: fgljbwing substarires: alra marijuana, or other drug or medication of any kind (prescription or not)? If (a) the name; ;so, for each person state: (b) the daites each was used; (a) the name, ADDRESS, and telephone number; (c) the state and county of each fictitious nanie filing; and (b) the nature or description of each substance; (d) the ADDRESS ofthe prindpal pla(::e; of business. (c) the quaritjty of each substahre iised or taken; I n I 3,7 ywthiri the past five years has any public entity (d) the date and time of day when each substaiice was registered or licensed your business? If so, for each licerise used oi^ taken; or registration: (e) the ADDRESS where each substance was used or (a) identify the license bi" registration; takeo- ff) the name, ADDRESS, arid telephoneriurriber,bf each (b) state the riame of the publjc entity; and person who vyas jDreseht Wheri each substance was (c) state the dates bf issuance arid expiration. used or taken; and 4.0 Insurance (g) the name, ADDRESS, and telephone riiirtiber of any I I 4.1 At the time of the INCIDENT, was there in effect any HEALTH CARE PFtOVIDER who prescribed or policy of irisui'arice through which you yvere or might be furnjshed the substance and the condition for which it insured in any manner (for example, primary, pro-rata, or was prescribed or furnished. excess liability coverage br riiedical expense coverage) fbr 3.0 General Background Infonnation—Business Entity the darriages, daims, br actioiis that have ariseri Put of the INCIDENT? If .so, for each policy state; I « I 3.1 Are you a corporiatibn? If so, state: (a) the name stated in the curi'erit articles of incorporation; (a) the kind of coverage; (b) all pther names used by ttie corporation during the past (b) the riame arid ADDRESS ofthe insurarice company; 10 years and the dates each was used; (c) the nanie, ADDRESS, and telephone number of each (c) the date and place of incorporation; named insured; (d) the ADDRESS of the prindpal place pf business; and (d) the policy riunriber; (e) whether you are qualified tb dp biisiriess in Califoririia, (e) the limits of coverage for each type of coverage I « I 3.2 Are you a partnei^ship? If so, state: contained in the pblicy; (a) the currerit partnership riame; (f) whether any reservation of rights pr controversy or (b) all other names used by the partnership during the past coverage dispute exists betyveen ypu and the 10 years and the dates each was used; insurance company; and (c) whether you are a limited partnership and, if so, iirider (g) the name, ADDRESS, and telephone number of the the laws of what jurisdiction; custodian of the pblicy. (d) the name and ADDRESS of each general partner; and I I 4,2 Are you self-insured urider any statute for the (e) the ADDRESS of the principal, place bf business, damages, daims, or actions that have arisen out of the I * I 3.3 Are ybu a limited liability cphipariy? If so, state; INCIDENT? if so, specify the statute. (a) the nanie stated in the current articles of organization; 5.0 [Reserved] (b) all other names used by the cornpany iJuririg tiie past 6.0 Physical, Mental, or Ernptipnal Injuries 10 years aind tlie date each was used; 1 I 6.1 Do you attribute any physical, mental, or ernotional (c) the date and place bf fjlihg of the articles of injuries to the INCIDENT? (If ydiir answer is "no, " do r7o( organization; ariswerinterfqgatqries 6.2 thrpugti 6.7). (d) the ADDRESS bf the principal place bf buisiness; and 1 I 6.2 Identify each injury you attribute to the INCIDENT and (e) vyhefher you are qualified tp do business in Califpmia. the area of your body affected. DISC-001 [Rev. Januaiy 1. 2008] FORM I N T E R R O G A T O R I E S — G E N E R A L Page 3 of 8 DISC-001 J 6-3 Do you still have any complaints that you attribute to the (c) state the amount of .damage yPu are dairnirig for INCIDENT? If so, for each cpmpiaint .state: each item bf prpperty and hpyv the ampuht was calculated; and (a) a descjiptipn; (b) whether the complaint is subsiding, remaining the (d) if the property was spld, state the riiarne, ApbRESS, same, or becoming worse; and ariii te|ephpne number of the seller, the date of sale, and the sale price. (c) the frequency and duration. 2] 6.4. Did ybu receive any cpriisultafion or examinatipri (except I I 7.2 Has a written estimate or evaluation been made foi" ariy from expert yi/itnesses cpyered ,by Code of CiviJ Procedure item of property referred to in your answer to the preceding sedioris 20i*.21(>^^ or treatment from a HEALTH interrbgatory? If so, for each estiniate or eyaluatipn state:, CARE PROVIDER for any injury you attribute to the (a) the name, ADDRESS, and telephone humbel' Pf the INCIDENT? if so, for each HEALTH CARE PROVIDER PERSON yvhb prepared it and the date prepared; state: (b) the name, ADDRESS, and telephone number of each (a) the h^ame, ADDRESS, and teiephone number; PERSON who has a pppy of it; and (b) the type of cprisiiltatipri, examination, or treatment (c) the amount of damage stated. provided; (c) the dates you received consultation, examination, or I I 7.3 Has any iterfi bf.pfbperty referred to in your ansvver to treatment; and intenrogatory 7.1 been repaired"? If so, for each iterii statie: (d) the charges to date. (a) the date repaired; ^ 6.5 Have ybu taken any medicatibn, prescribed or not, as a (b) a description of the repair; result pf injuries that ypu attribute tp the INCIDENT? if so, (c) the repair cost; for each medication state: (d) the name, ADDRESS, arid telephone riufriber pf the (a) the iiame; PERSON vyhb repaired it; (b) the PERSON who prescribed Pi" fumished it; (e) the name, ADDRESS, arid telephone number bf the (c) the date it yvas prescribed, pr furnished; PERSON who P^id for the repair (d) the dates you began and stopped taking it; and 8.0 Loss of Incoitie or Earning Capacity (e) the cPst tp date. I I 8,1 Do you attribute any loss of income or earning capacity 6,6. Are there any other medical services necessitated by the inj