Agenda - Council - 06/12/2007 - Special

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06/07/2007 14:44 LAW OFFICE 2140 4TH AUE ~ 4339898 NO. 462 [;109 (I) Full names; (2) Age; (3) Current or last knO\VIl address and telephone number; . (4) Current or last known employer and position with employer. INTERROOA T()RTF'~ 1. Identify the person or persons signing these Answers to Interrogatories and identity every other person assisting in the preparation of the Answers. 2. List [he names of any persons referred [0 in your Answer to Interrogatory I whom you have interviewed, and state the date, time and location of each intemew, and identify each person conducting, or otherwise present at, each interview. J, Have t,here been any statements taken or received relating to the matters alleged in the Complaint? If so: (a) Identify each person from whom you have taken a statement, indicating whether the statement was oral, wrinen, by a 'court reporter, tape-recorded or otherwise preserved and any other person present during the, taking of the Statement. (b) State the date, time and location of each statement and whether the person from whom the statement was taken has been provided with a copy, specifying the date and place thereof. 4. Please provide the names and addresses of all individuals you ,may call as witnesses in the Ilial of this matter. For each such person, indicate the substance of their expected testimony. I 5. Identify each exhibit which you intend to offer at the time of trial of tlUs lawsuit; for each exhibit., state its iSUbject nianer, the name and address of the person who created the exhibit. the name and adpress of its present custodian, the date when the exhibit was creared, and the purpose for which the exhibit will be offered at the time of trial. . I 6, With respect to Jach person that you are intending to have testify as an expert witness, state the following; . (a) The subject matter on which he is expected to 'testifY; (b) The substance ~fthe facts and opinions to which he is expected to testify; (c) A swnmary of the gr,ounds for each opinion including the specific data upon which the opinion would be based. 7. Ifyou,,~laim there has been'improper and/or insufficient service of process upon you, state in detail-and with panicularity all facts in support of your claim. 2 , .