Just Received Defendants First Set of Interrogatories!

[RealtorKen]

Remember Federal Court

Well here they are:

1. Identify the person or persons answering these interrogatories

2. Identify the location and address of Plainiff's office and/or residence in addition to any other physical addresses and locations at which Plaintiff conducts business or resceives correspondence.

3. Identify the names, addreses and telephone numberss of all persons who have personal knowledge of any of the facts, events, or matters that are allefed in Plaintiff's complaint, and describe and explain your understanding of the matters on which the persons named have knowledge.

4. Identify all correspondence or documents that refer or relate to any communication between Plaintiff and Defendant in this action, as well as any matters alleged in Plaintiff's Complaint.

5. Identify each person who you may call as a witness at trial including name, business address, telephone number and the substance of the facts and opinions to which the witness may testify and summarize the grounds for each opinion.

6. With respect to Interrogatory 5, specify the capacity in which person acted with regard to this action and the role played by each person therein, including specific dates and locales.

7. State where plaintiff first opened a AT&T wireless account and attach hereto copies of all invoices, contracts, mormorandums and documentation sent by AT&T Wireless to Plaintiff.

8. If Plaintiff terminated the AT&T Wireless accounts, attach hereto copies of all correspondance to AT&T Wireless with regard to termination to said account.

9. If Plaintiff disputed any amount owed to AT&T Wireless, attach hereto copies of all correspondance to AT&T Wireless with regard to said disputed amount and responses from AT&T Wireless, their agents, and/or assignes.

10. State the amount plaintiff owed AT&T Wireless when the account in question was terminated and if Plaintiff paid or satisfied said account, attach hereto copies of cancelled checks and/or memoranda evidencing said satisfaction.

11. As to Count one of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

12. As to Count Two of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

13. As to Count Three of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

14. As to Count Four of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

15. As to Count Five of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

16. As to Count Six of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

17. As to Count Seven of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

18. As to Count Eight of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

19. As to Count Nine of Plaintiff's Complaint set forth in detail all facts Plaintiff plains to rely on in support of said allegations, list any documents, written communications, and oral communications not heretofore mentioned in answers to the preceding interrogatories upon which plaintiff intends to rely in proof of its alleged damages.

CERTIFICATION

I hereby certify that the copies of the written reports or complete summaries of any oral reports of treating physicians or expert witnesses, annexed hereto, are exact copies of the entire written report or reports or comple summaries of any oral report or reports rendered by them; that the existence of other reports of treating physicians or expert witnesses,whether written or oral, are unknown to me; and that if such reports become later known or available, I shall serve them promptly upon the propounding party, but in no case later than the time prescribed by the Rules of Court.

I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.