IN THE GENERAL COURT OF JUSTICE
COUNTY OF LONDON
STATE OF PLACID
CIVIL ACTION FILE NO: 00-X-0000-0

Jack Cherry(Plaintiff) v.Big Buys, Inc.(Defendant) | PLAINTIFF’S FIRST INTERROGATORIES TODEFENDANT |
To: Defendant Big Buys, Inc. I herewith serve upon you the following written interrogatories under the provisions of Rule 33 of the Rules of Civil Procedure. You are required to answer these interrogatories separately and fully in writing under oath and to serve a copy of your answers on the undersigned within 30days after service hereof. These interrogatories shall be continuing in nature until the date of trial, and you are required to serve supplemental answers as additional information may become available to you. 1. Identify any individual that you are aware has personal knowledge of the facts and circumstances of this case, including eyewitnesses and any individuals who arrived on the scene within two hours after the occurrence. Answer: 2. If anyone investigated this matter for you, but not limited to employees, agents, supervisors, corporate personnel, private investigators, or insurance adjusters, state their names(s) and address (es), and state whether such investigation was reduced to writing. If said investigator obtained any signed statements or recorded statements, identify the person who gave the statement and attach to your Answers a copy of any said statement. Answer: 3. If you know of the existence of any pictures, photographs, charts, diagrams, recorded images, videotapes, digital media, or objects relative to the attack on the Plaintiff on the day and time alleged in the Complaint, the Plaintiff’s physical condition, or the scene of the occurrence, identify the substance of such recording and the present custodian of each such item. Answer:

4. Please list all insurance agreements you have regarding the store location, the corporation or other policy that may, in any way, have any bearing on the occurrence, including, the name of the insurance company, the amount of coverage (specifying its upper and lower limits), and the effective dates of said policy for the past five (5) years. (a) In answering this interrogatory, take into consideration all policies possibly affording coverage, including any excess or umbrella policies which might afford coverage to you; (b) if there is any questionable liability insurance coverage, state the basis for denying or questioning the coverage that might be afforded. Answer: 5. State all store and/or corporate policies regarding premises liability, injuries to customers, investigation of accidents or injuries to customers, whether ruled accidental, negligence, or intentional actions by third parties. Answer: 6. State the name and address of each person whom you expect to call as an expert witness at trial, and state the subject matter on which the expert is expected to testify, and for each such expert identifies, state the following: (a) The substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion; (b) the identity of any and all documents submitted or supplied to the expert in connection with his or her opinions and testimony ; and (c)