INTERROGATORIES- Instructions / Disclaimer:

Oncea civillawsuit is commenced,a partyis permittedto seekto obtaininformation about other partiesto thesuit during the fact-finding phase before trial, called Discovery. In general, parties may obtainDiscovery about any matterwhich is relevantto the subjectmattei invo-lvedin the pendin! action,so long as the information is notprivileged. General provisions governing Discovery aie founl in Rule26 of the NevadaRules of CivilProcedure ('NRCP). Informatlonabout each of thedifferent Discoverytools available to partiesto a lawsuit,and howthey may be used,is foundin NRCp30 through36.

Interrogatoriesto Partiesare formalwritten questions, provided for by NRGP33, which a partymay ask anolher party during Discovery.Each pafi is allowedto serve up to 40 Interrogatories-' includingrelated sub-parts -- on anotherparty. You may not serve more than 40 Interrogatories withoutprior permission, which is obtainedby first filing a motionwith the Courtseeking leave to do so.*1*

The partyupon whom the Interrogatoriesare served must serve a copyof itsanswers and objections, if any,within thirty (30) days after being served. A shorteror longertime maybe directedby the court,or agreedto in writingby the parties,so longas the timeto responddoes not interfere with any timeset for completionof discovery(See, Rule 29).

EachInterrogatory must be answeredseparately and fully in writing under oath, unless it is objected to. In suchevent, the objectingparty must specifically state the groundsfor objection,and muststill answerthat portionof the interrogatorythat is not objectionable.Any groundnot statedin a timely objectionis waived, unless the party'sfailure to objectis excusedby the Courtfor goodcause shown.

Provided[below] are sampleInterrogatories which mayassist you in discoveringcertain important informationabout other partiesthat will be helpfulto your case. These Interrogatoriesare fundamentalin nature,and are not intended to be anall-inclusive compilation of what you may need to knowin orderto proveyour entirecase.

DISCLAIMER:THE COURTDOES NOT etVE LEGALADvtCE

lf you need assistance in determining the appticability of any Interrogatories, or the comprehensiveness of the sample Interrogatoriesprovided below to your case,you are encouraged to obtain the advice of a legal professional licensed to practice in Nevada. Professionallegal advice may also be of assistanceto youconcerning the useof anyof theother forms of discoverableinformation provided for in CourtRules 30 through36.

Pleaseuse only thoselnterrogatories thatapply to the particularsof your own case,e.g, those thatwill enable you to discover to information you will need to prove the facts of your case. Not all of these Interrogatoriesapply to every type of case or set of circumstances,and the Court maynot requirean opposingparty to answersome or all of your lnterrogatoriesif they do not apply to the facts of your case.

1 PLEASENOTE: lf yourcase is in the MandatoryArbitration program, the number of interrogatoriesyou are entitledtO ask may be furtherlimited by the Arbihator. lnterrogatoriesfrom Plaintiff to Defendant

General

Stateyour name,each nameyou have used in the past,and the datesyou used eachname. Statethe dale and placeof your birth. Stateyour currentresidence address, your residenceaddresses for the past five years,and the datesyou livedat each address. Describeyour formal education, including the nameof eachschool attended, the dateswhen you attendedeach schooland whetherany degreeor certificatewas obtainedfrom each school. ldentifywith specificityand detailall expertwitnesses whom you expectto call as a witnessat trial.For eachsuch expertwitness, state the subjectmatter on which s/he is expectedto testifu;the substanceof the facts and opinionsto which the expertis expectedto testiry;and a summaryof thegrounds for eachopinion. ldentifywith specificityand detail all documentaryevidence in your possession, custodyor controlrelated to the claimsalleged in the Complaint.For eachitem identified,state the full nameand addressof the recordcustodian, the locationof the document,and the name(s)of all person(s)who havebeen provided with a copy. Pleaselist each and everyexhibit that you intendto haveadmitted into evidence at the timeof trialand for eachexhibit please state: a. The name, professionalstatus, job title, and addressof each individualwho presentlyhas custody of the originalof the exhibit. b. The name,address, job title,and professionalstatus of eachand everywitness from whom you will,at the time of trial,elicit testimony to admitthe exhibitas evidence. Pleaseidentiff all documentsin yourpossession which support your responses to these interrogatories. ldentifoeach person, other than counsel,who providedinformation or assistedyou with respectto the preparationof the answersto the foregoinginterrogatories, and identifythe specificinterrogatories for whicheach personprovided information or assistance,and the substantiveinformation provided by eachperson and / or the type of assistanceeach person rendered. At the time of the eventsalleged in the Complaint,was therein effectany policyot Insurancethrough which you were or mightbe insured in any manner. lf so,for each policystate: a. the nameand address ofeach insurer; b. the name,address, and telephone number ofeach namedinsured: and c. whetherany reservations of rightsor controversyor coveragedispute existsbetween you and the insurancecompany. Areyou self-insured under any statute for thedamages, claims, or actionsalleged in the Complaint? lf youcontend that someone otherthan you is responsible,in wholeor in part,for the damagesalleged in the Complaint,please state all facts supportingyour contention. Foreach denial of a materialallegation and each special or affirmativedefense in yourpleadings, for eachstate all facts upon which you base the denialor special or affirmativedefense. [o be usedonly after initialdiscovery takes place.]

Breach of Oral and Written Agreementor Contract . Foreach agreement alleged in the Complaint,please identi! allspecific breaches of the agreement(s)that you contendare at issuein this matter,including the date of each breachand the act or omissionconstituting the breach. . Was the performanceof anyagreement alleged in the Complaintexcused? lf yes, identiffthe agreementexcused and statewhy performancewas excused. . Was any agreementalleged in the Complaintterminated by mutualagreement, release, accord and satisfaction,or novation? lf yes, please identify each agreementterminated, the date of termination,and the basisof thetermination. . ls any agreementalleged in the pleadingsunenforceable? lf yes, identifyeach unenforceableagreement or partthereof and statewhy it is unenforceable. . ls any agreementalleged in the Complaintambiguous? lf yes, identifyeach ambiguousagreement or partthereof and state why it is ambiguous.

Employment . lf you contendthe PlaintiffwasAras not terminated,please state all facts upon whichyou baseyour contention. . lf the Plaintiffwas replacedin his/herposition, please identiff the sex,race, age, and rateof pay of the personwho replacedPlaintiff. . Do youmaintain an EmployeeHandbook containing policies and procedures with whichyour employees must comply, and bywhich the companyoperates. State all facts, if any, that wouldsupport the Plaintiffstermination that were first discoveredafter the termination? Pleasestate all reasonsfor the Plaintiffstermination. Pleasestate all policiesand proceduresthat you contendPlaintiff violated while employedby you. Pleasedescribe all disciplinereceived by Plaintiffwhile employed by you. Personallnjury . Haveyou ever had a vehicledrive/s licensesuspended, canceled, or revoked? lf so,state the name of the state suspending, canceling or revokingsuch license, with the date(s)of suchand reason(s)therefor. . Haveyou receiveda trafficviolation notice and/or citation within the five (5) years precedingthe accident?lf so, statefor eachthe nameof the cityand state of the incident,the date(s)of such,the citationand/or violation charges, the reason(s) therefore,and the disposition(s)thereof. . lf you were involvedin the accidentor incidentthat is the subjectof this case, pleasestate the date,time, and location of the accidentor incident. . lf you were involvedin the accidentor incidentthat is the subjectof this case, pleasestate the speedat which you were travelingat the time of the accidentor incident. . lf you were involvedin the accidentor incidentthat is the subjectof this case,and werestopped at the timeof the accidentor incident,please state the reason(s)you were stopped. . lf you were involvedin the accidentor incidentthat is the subjectof this case, describethe weatherand roadconditions that existed at the timeof the accidentor incident. . lf you were involvedin the accidentor incidentthat is the subjectof this case, describeyourviewto the north,south, east and west, and state whether anything obstructedyour view in any directionat the time of the accidentor incident. lf you were involvedin the accidentor incidentthatis the subjectof thiscase, state your intendeddestination, and the routeto be used. lf you were involvedin the accidentor incidentthat is the subjectof this case, describethe detailsof the incidentin your ownwords, describing factually (without legalconclusions), what caused the accidentor incidentto happen. lf you were involvedin the accidentor incidentthat is the subjectof thiscase, state the name,address, and phone number of eachperson you spoke to atthe accident or incidentscene, including any and all witnesses you are aware of. lf you consumedany intoxicating beverage(s) within 24 hourspreceding the subject accidentor consumedany type of legal or illegaldrug, narcotic, sedative or any otherkind of medicationwithin one (1) week preceding the subject accident at issue herein,please state the following: a. thetime and place of eachuse or consumption;and b. the kindand amount of suchitems used or consumed. At thetime of thesubject incident, did a policyor policiesof liabilityinsurance cover you? lf so, statefor eachpolicy the name,address and telephone number of the insurer,the nameand address of the namedinsured(s), the numberof the policy, the effectivecoverage dates thereof, the natureof the coverages(s),the limitsof liabilitycoverage (as to each coveredperson) and the nameand addressof the custodianof the policy. were you chargedand/or cited by anygovernmental authority with a violation(s)of any haffic or other law as a resultof your conductand/or ihe operationof your vehicleprior to and/orduring the occurrence of the subjectincident? lf so, please statethe charge, any plea(s) entered, and the dispositionof the citation(s)and/or chargesthereof. lf yourvehicle involved in the incident in questionsustained any damage, visible or otherwise,state the natureof that damage,the locationof the vehicle,cost(s) of repair,and the individual or entity performing the repair, along with their address('es) and phonenumber(s). lnterroqatoriesfrom Defendantto Plaintiff

General

. Stateyour name, each name you haveused in the past,and the datesyou used eachname. . Statethe dateand place ofyour birth. . Stateyour currentresidence address, your residenceaddresses for the past five years,and the datesyou livedat each address. . Describeyour formal education, including the nameof eachschool attended, the dateswhen you attendedeach schooland whetherany degreeor certificatewas obtainedfrom eachschool. . ldentifywith specificityand detailall expertwitnesses whom you expectto call as a witnessat trial. Foreach such expertwitness, state the subjectmatter on which s/he is expectedto testify;the substanceof the facts and opinionsto which the expertis expectedto testify;and a summaryof the groundsfor each opinion. . ldentifywith specificityand detail all documentaryevidence in your possession, custodyor controlrelated to the claims allegedin the Complaint.For each item identified,state the full nameand addressof the recordcustodian. the locationof the document,and the name(s)of all person(s)who havebeen provided with a copy. ' Pleaselist each and every exhibit that you intendto haveadmitted into evidence at the timeof trialand for eachexhibit please state: a. The name, professionalstatus, job title, and addressof each individualwho presentlyhas custody of the originalof the exhibit. b. The name,address, job title,and professionalstatus of eachand everywitness from whom you will,at the time of trial,elicit testimony to admitthe exhibitas evidence. . Pleaseidentify all documents in yourpossession which support your responses to these interrogatories. . ldentifyeach person, otherthan counsel, who providedinformation or assistedyou with respectto the preparationof the answersto the foregoinginterrogatories, and identifythe specificinterrogatories for whicheach personprovided information or assistance,and the substantiveinformation provided by each personand/or the type of assistanceeach personrendered. . lf you dispute the authenticityor validig of the documentsattached to the Complaint,please state all facts upon which you base your dispute. . lf you contendthe documentsaftached to the Complaintdo not accuratelyreflect yourunderstanding of thefacts of thisdispute, please explain the facts upon which you rely. ldentifyall individualsor witnesseswhom you believe have personal knowledge of the actionsand events described in yourcomplaint, and providetheir full nime. address,and telephonenumber, along with a summaryof what facts and knowledgeyou believethey have.

Breach of Oral and Written Agreementor Contract ' Foreach agreement alleged in thecomplaint, please identify all specific breaches of the agreement(s)thatyou contend are at issuein this matter, including the date of each breachand the act or omissionconstituting the breach. ' was the performanceof any agreementalleged in the complaintexcused? lf yes, identifythe agreementexcused and statewhy performancewas excused. ' was any agreement.alleged in the complaintterminated by mutualagreement, release, accord and satisfaction,or novation? lf yes, please iOeitify each agreementterminated, the date of termination,and the basisof the termination. ' ls any agreementalleged in the pleadingsunenforceable? lf yes, identifyeach unenforceableagreement or partthereof and statewhy it is unenforceable. ' ls any agreementalreged in the compraintambiguous? lf yes, identifyeach ambiguousagreement or partthereof and state why it is ambiguous. ' For each agreementalleged in the complaint,please identify the partiesto the agreement,the executiondate, and generalnature of the agreement.

Employment ' lf you contend the Plaintiffwas/was not terminated,please state all facts upon whichyou baseyour contention. ' Pleaseidentifuthe name, address and telephone numberof each of youremployers priorto thetime you were hired by Defendant,including the dates of emptoyment. ' lf currentlyemployed, prease provide the nameand address of youremproyer. ' lnthe lastfive(5) years, haveyou received any federalor state government benefits for disability,unemployment, retirement, health care, sociaisecurityor welfare benefitof any nature? rf so, preaseidentify each specific benefit received. ' lf youapplied for employmentwith any company since the date of theevents that gave rise to this laws.uit,please identify the name, address,and date(s) of applicationof eachsuch company where you haveapplied for employment. ' Exceptfor this action,within.the past 10 years,have you filed any lawsuitor administrativecharge related to your employmentat any cuneni or former employer? lf yes, preasestate the date of eaih action/charge,and the court or administrativeentity with whom it was filed. ' 'at Do you contendthe em.proymentrelationship was not wilr?,,rf yes, state all facts uponwhich you basethis contention. Do.youcontend the emproyment rerationship was governed by any agreement - written,oral, or implied?lf yes,state all facts upon w-hi"h yo, uaie y6ur"cont"ntion. thatany of theemptoyer,s actions against you were discriminatory, preaseLf:^":I:lg rdentifyeach action, the date on whichit occurred,and the basis for your contentionthat the action was discriminatory. lf you contendyou were harassedin the workprace,prease state ail factsthat supportyour contention, including each specific incident, the date of each incioeni, andthe person(s) engaging in the harassing behavior. lf you contendyou were harassed/discriminated against in theworkplace. did vou tlrecgnguct Igpo,rt to youremployer. tf yes,pteaseitate the Oates Voi'Lpoilil; conductand the person to whomyou reporteO. Did.the employeefire a craim,.compraint, orcharge with any governmentar agency thatinvolved any of themateriar aregations madE in ttre cffitainta identifu iiG,;i;;;; thedate on which it wasfirei, tne agencywiih which it wasnreo, ahJine natureof thecharges contained in the claimi, complaint, or charge.

PersonalInjury ' Haveyou ever had a vehicredriver's ricense suspended, cancered, or revoked?rf so' statethe nameof the statesuspending, cancering or revokingsuch ricense, witn the date(s)of such and reason(s)theredL. ' Haveyou receiveda trafficviolation notice and/or citation within preceding the five (5) years the accident? rf so, statefor eachthe nameof the city incident, anJ sia'L or tne the date(s)of such, the citationand/or vioration chargLs, irre-reasonlsy therefore,and the disposition(s)thereof. ' you lf were involvedin the accidentor incidentthat is please the subjectof this case, statethe date,time, and location of theaccident or incident. ' you lf were invorvedin the accidentor incidentthat is please the subjectof this case, state the speed at whichyou were travelingat the time incident. 6i irre accioentor ' lf you were invofuedin the accidentor incidentthat is the subjectof this werestopped case,and at the timeof the accidentor incident,prease stite the ,.""-1.; were stopped. yo, ' lf you were invorvedin the accidentor incidentthat is the subject describe of this case, the weatherand roadconditions that existed at the time incident. of the accidentor ' lf you were invorvedin the accidentor incidentthat is the subject describeyour of this case, viewto.the north, south, east and west,and statewrrettrei'anyttrrng obstructedyour view in any directionat the time of the accident i;;id;. ' lf you were invorved "; in the accidentor incidentthat is the subjectof thiscase, state yourintended destination, and the routeto be used. ' lf you were involvedin the accidentor incidentthat is the subjectof this case, describethe details oJ the incidentin your own words, describing factually (withoui legalconclusions), what caused the accidentor incidentto haplen. ' lf youwere involved in the accidentor incidentthat is the subjectof this case,state thename, address, and phone number of eachperson you sfoke to atthe accident or incidentscene, including any and all witnesses you are aware of. ' lf youconsumed any intoxicatingbeverage(s) within 24 hourspreceding the subject accidentor consumedany type of legalor illegaldrug, narcotic, sed'ative or any otherkind of medicationwithin one (1) week pre&Oing ttre suOlect accident at issue herein,please state the following: a. the timeand place of eachuse or consumption;and b. the kindand amount of suchitems used or consumed. ' At thetime of thesubject.incident, did a policyor policiesof liabilityinsurance you? cover lf so, statefor eachporicy the name,iddress and terepho'ne num[er or me insurer,and the nameand addressof the namedinsured(s), the number policy, of the the effectivecoverage dates thereof,the natureor'tni coveiales(s),the lim.itsof liabilitycoverage (as to eachcovered person) and the n"m" address of the custodianof the policy. "nd ' were y9_u chargeda.nd/or cited by anygovernmental authority with a violation(s)of any traffic or other.raw.as a resurtof your conductand/or ihe op",."tion-ii of your vehicleprior to and/orduring the occurienceof the subjectincioenti so, prease state the charge,any prea(s)entered, and the dispositionof the citation(s)and/or chargesthereof. ' your lf vehicleinvolved in theincident in questionsustained any damage, visible otherwise, or state the natureof that damage,the rocationof the vehicie,'cos(s)of repair,and the individual or entity performing the repair, along with their address(es) and phonenumber(s). Damages ' For eachitem of damagesyou craim in this action, prease identify a[ personsupon whomyou will rely to supportyour damages. ' For each item of damagesyou craimin this action,prease state the amount damages of you are seeking,ano the basisupon which you computetni amount. ' For eachitem of damagesyou craimin thisaction, prease identifu ail documents uponwhich you willrely upon to supportyour damages. ' Do yor attribure anyphysicar, mentar, or emotionarinjuries to the craimsmade in your compraint. rf yes, identifywith specificityeach inlury you aftributeto the conductalleged in yourComplaint. ' lf you attributeany physical,mentar, or emotionarinjuries to the conduct your ailegedin complaint,prease state whether you have sought treatment for those injuries. ' lf y9, havesought treatment for any physicar,mentar, or emotionarinjuries to rerated theconduct aileged in your compiaint, prease identify by n",n" iaai""" "nJ """n treatmentprovider, thedates of treatment,the treatment received, and any out-of- pocketexpenses related to saidtreatmeni-' lf youmake a claimfor rostincome, state the totar amount of income, earning benefits,or capacityyou have lost to dateand how the amount was calculated. lf youmake a claimfor rost income, prease specifo ail efforts you engaged in to find worksince your last date of workwittr OeferiOant. lf you makea claimfor rostincome, prease itemize ail incomeyou have received, includingall sources, from the date of terminationio ine present.