SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA NO. C126447
HAROLD BENNETT,
Plaintiff,

vs. INTERROGATORIES SOUTH WESTERN HOSPITAL
Defendant.

TO: DEFENDANT, SOUTH WESTERN HOSPITAL
TO: JOHN DONG

Under the authority of Rule 33 of the (Title of Rules), Plaintiff, by and through its attorneys, request that Defendant, answer, in writing and under oath, within 30 days of receipt hereof, the interrogatories hereinafter set forth.

DEFINITIONS

1. "COMPLAINT" shall mean and refer to Plaintiff's complaint originally filed on 08-10-15 in Department XVII of the Santa Clara County District Court, Case No. C126447.
2. "PROPERTY" shall mean and refer to the real property owned by the Defendant.
3. "YOU", "YOUR", "YOURS", and/or "DEFENDANT" shall mean and refer to as well as, his agents, attorneys, employees, accountants, family members, investigators, or any other person acting on his behalf.

INTERROGATORIES

INTERROGATORY NO. 1:

Describe in detail the number of employees and each employee’s job duties on the date of the incident in this case.

INTERROGATORY NO. 2:

Identify any warning, caution, "wet floor", or other relevant signs that were displayed in the area where the incident occurred, including their verbiage, size and exact location.

INTERROGATORY NO. 3:

Please provide the full name, title, address and phone number of each employee present in the building at the time of this incident.

INTERROGATORY NO. 4:

Prior to this incident, when was the last time the floor area where the incident occurred was washed or sanitized? Please provide the approximate date and time as well as the name of the individual(s) responsible for such cleaning.

INTERROGATORY NO. 5:

To your knowledge, did anyone see Mr. Bennett fall? INTERROGATORY NO. 6:

Please state the name, address and job title of any employee from whom Plaintiff asked for assistance after his fall on June 1, 2015.

INTERROGATORY NO. 7:

Please state the name, address and job title of each employee or agent of defendant who is directly above or supervisory to Kevin Porter.

INTERROGATORY NO. 8:

Identity any document written, created, filed in, produced, or utilized to document the slip and fall incident suffered by Plaintiff on June 1, 2015.

INTERROGATORY NO. 9:

Please state the name, address and job title of any employee or agent of this Defendant who came to Plaintiff's aid after he slipped and fell June 1, 2015.

INTERROGATORY NO. 10:

Please state the name, address, and job title of any person who prepared any documentation regarding the slip and fall suffered by Plaintiff on June 1, 2015.

INTERROGATORY NO. 11:

Please state, at the time Plaintiff reported that he had fallen on June 1, 2015 what his condition was, including whether he was able to stand, or walk without assistance.

INTERROGATORY NO. 12:

State whether any policy or policies of insurance exist which may provide coverage to this Defendant for any liability, which may arise as a result of the incident referred to in Plaintiff's Petition.

INTERROGATORY NO. 13:

State the name and address of the Insurer.

INTERROGATORY NO 14:

State the policy number and amount of liability insurance coverage afforded by each such policy.

INTERROGATORY NO. 15:

Identify each retained expert witness, including employees of the Defendant, whom you expect to call at trial to provide expert witness testimony.

INTERROGATORY NO. 16:

State full address, occupation, place of employment and qualification of each such expert witness.

INTERROGATORY NO. 17:

Attach a copy of expert's curriculum vitae.

INTERROGATORY NO. 18:

Was any employee to agent of this Defendant disciplined or reprimanded in any way or terminated as a result of slip and fall incident suffered by Plaintiff on June 1, 2015?

INTERROGATORY NO. 19:

Other than the incident that is the subject matter of this lawsuit, have any other slip and/or fall incident occurred at the location of this accident, within the past five years? If so, please provide the date, parties name, nature of the incident and lawsuit information (if any) regarding each such incident.

INTERROGATORY NO. 20:

Please list the names of all the directors and human resource personnel of this Defendant. DATED this 15 day of September, 2015.

JOSEPH ASTOR
Bar No: 98354
3591 Oracle Circle
San Jose, California
Attorneys for Plaintiff,

CERTIFICATE OF MAILING I hereby certify that on this 15 day of September, 2015, I placed a true and correct copy of the foregoing INTERROGATORIES TO DEFENDANT in the United States Mail, postage prepaid, addressed to counsel on the attached service list: Mary Smith An employee of JOSEPH ASTOR