Plaintiff: Natal Hatter

v. REQUEST FOR INTERROGATORIES Index No: _101__
Defendant: Smart Deal, Inc.

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Plaintiff requests that Defendant respond to the following interrogatories separately and fully in writing and under oath, pursuant to statute 2030 of the Virginia Code Of …show more content…
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Plaintiff requests that Defendant respond to the following interrogatories separately and fully in writing and under oath, pursuant to statute 2033 of the CPLR and that the response be signed by the person making them and be returned to Margaret Reid at the Law Office of Reid and Stern, 800 Jones Branch Ave, Manassas, VA 20116 within thirty (30) days after service of these interrogatories.
FAILURE TO TIMELY SERVE WITH VERIFIED RESPONSES, DEFENDANT SHALL WAIVE OBJECTIONS AND PRIVLEGES AND THE REQUESTS MAY BE DEEMED ADMITTED.
1. Admit that this Foods Deluxe store owns the responsibility of a safe environment to its customers.

2. Admit that by failing to ensure safe operations of store conveyor belts, Foods Deluxe failed that duty.

3. Admit that the conveyor belt that caught Mrs. Hatter’s clothing was the main cause of her …show more content…
REQUEST FOR PRODUCTION OF DOCUMENTS Index No: _103_
Defendant: Smart Deal, Inc.
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Pursuant to statute 2031 of the Manassas, VA Code of Civil procedure, Plaintiffs, by and through their attorneys, hereby demand that the Defendant produce for discovery, inspecting and copying at the Law Offices of Reid and Stern, 800 Jones Branch Ave, Manassas, VA 20116,the following documents and material.
DOCUMENTS TO BE PRODUCED

1. Please provide legal copies of each insurance policy for Foods Deluxe.
2. Please provide any documents with regards to the regular schedule of maintenance for conveyor belts used at this store.
3. Please provide all photographs and surveillance videos of the