Interrogatories[1]

i _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 INTERROGATORIES WHAT IS THE DOCUMENT? Written questions (either form or specially drafted) between parties that request information or the identification of documents or persons relevant to the issues in the lawsuit. WHAT ARE THE APPLICABLE STATE/LOCAL COURT RULES? 1. CCP § 2030 SPECIAL RULES OR OTHER REQUIREMENTS 1. May only be served on other parties 2. Plaintiff must wait 10 days after the defendant is served with the complaint or appears in the action before serving interrogatories. Defendant can serve interrogatories at any time. 3. No preface, instructions or subparts (including compound, conjunctive or disjunctive questions) permitted in specially drafted interrogatories. 4. No party may serve without leave of Court more than 35 specially drafted interrogatories on any other party [EXCEPTIONS: Form interrogatories and supplemental interrogatories (which can be served twice before any trial date is set and once after) do not count against the 35 limit; Party may serve additional interrogatories if accompanied by declaration pursuant to CCP § 2030(c)(3)]. 5. Party serving interrogatories keeps custody of originals and serves copies on the responding party and on all other parties ii _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 who have appeared in the action. Original responses must be verified by the responding party and served within 30 days if the interrogatories were personally served and 35 days if the interrogatories were mail served. 6. Parties may stipulate to extend the deadline to respond to interrogatories so long as extension in confirmed in a writing that specifies the new response date. 7. NOTE: Parties may stipulate to extend the time to complete discovery without leave of court although such a stipulation does not require the Court to continue the trial date of the action [CCP § 2024(f)]. 1 _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STEIN & ASSOCIATES Michael D. Stein (SBN 132540) 5235 West Allen Street Suite 200 Los Angeles, CA 90067 Tel: (213) 555-0994 Fax: (213) 555-0995 Attorneys for Defendant B-2 VIDEO INCORPORATED SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES SCOTT ALAN WOODWARD, Plaintiff, vs. B-2 VIDEO INCORPORATED, a California corporation; and DOES 1 through 20 inclusive, Defendants. ) ) ) ) )))))) ))) )) ) ) ) ) )) Case No.: ASSIGNED FOR ALL PURPOSES TO JUDGE JOHN SMITH Department 27 DEFENDANT B-2 VIDEO INCORPORATED’S FIRST SET OF INTERROGATORIES TO PLAINTIFF SCOTT ALAN WOODWARD ) PROPOUNDING PARTY: Defendant B-2 VIDEO INCORPORATED RESPONDING PARTY: Plaintiff SCOTT ALAN WOODWARD SET NO.: One 2 _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Code of Civil Procedure Section 2030, defendant B-2 Video Incorporated (“B-2”) requests that plaintiff Scott Alan Woodward (“Plaintiff”) answer the following interrogatories under oath within 30 days of service hereof. INTERROGATORY NO. 1: State all facts which support YOUR (For the purpose of these interrogatories, the terms “YOU” and “YOUR” shall mean plaintiff Scott Alan Woodward) allegation in paragraph 5 of THE COMPLAINT (For the purpose of these interrogatories, the term “THE COMPLAINT” shall mean the action YOU filed entitled “Scott Alan Woodward v. B-2 Video Incorporated, and Does 1-20” Los Angeles County Superior Court Case No. _____________) that “[B-2], and/or its agents, assured, promised and/or represented that Plaintiff would remain employed indefinitely and could only be terminated for good cause.” INTERROGATORY NO. 2: Identify all DOCUMENTS (For the purpose of these interrogatories, the term “DOCUMENTS” is used in the broad sense and includes, but is not limited to, anything coming within the definition of “writings” and “recordings” set forth in California Evidence Code Section 250) which memorialize, support, refer, relate to or pertain in any way to the facts set forth in YOUR response to Interrogatory No. 1. 3 _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 INTERROGATORY NO. 3: Identify all COMMUNICATIONS (For the purpose of these interrogatories, the term “COMMUNICATIONS” shall mean any transmission of any sort whatsoever, by one or more persons, to one or more persons, by any means whatsoever including, but not limited to, telephone conversations, letters, telegrams, e-mail transmissions, teletypes, telecopies, written memoranda, radio, cable, television, and face to face conversations) which memorialize, support, refer, relate to or pertain in any way to the facts set forth in YOUR response to Interrogatory No. 1. INTERROGATORY NO. 4: Identify all PERSONS (For the purpose of these interrogatories, the term “PERSONS” shall mean any natural person, firm, sole proprietorship, association, partnership, limited partnership, joint venture, corporation or other form of legal entity) who have knowledge of the facts set forth in YOUR response to Interrogatory No. 1. DATED: March 31, 2004 STEIN & ASSOCIATES By: _________________________________ Michael D. Stein Attorneys for Defendant B-2 VIDEO INCORPORATED 4 _______________ INTERROGATORIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss: COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action. My business address is 5235 West Allen Street Suite 200, Los Angeles, CA 90067. On March 31, 2004, I served the foregoing documents described as DEFENDANT B-2 VIDEO INCORPORATED’S FIRST SET OF INTERROGATORIES TO PLAINTIFF SCOTT ALAN WOODWARD on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Peter Crawford, Esq. 27255 Van Buren Road Torrance, California 93627 ___ BY MAIL I deposited such envelope into the Firm’s office mail at Los Angeles, California. I am readily familiar with the Firm’s practice of collection and processing correspondence for mailing. Under that practice, in the ordinary course of business, the mail is affixed with postage thereon fully prepaid and deposited with the U.S. Postal Service in Los Angeles, California on the same day. I am aware that on motion of a party served, service is presumed invalid if the postal cancellation date or the postage meter date is more than one (1) day after the date of deposit for mailing in this affidavit. ___ BY PERSONAL SERVICE I hand delivered such envelope to the offices of the addressee(s) listed above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed March 31, 2004 at Los Angeles, California. _____________________________ Harriet Evans