問卷示例
VIA REGISTERED INTERNATIONAL MAIL
May 18, 2006
DEFENDANT HODOWN CORPORATION’S FIRST SET OF INTERROGATORIES TO
PLAINTIFF SPORTS PROVIDERS, INC.
TO: Sports Providers, Inc.
C/o Larry Longer, Esq.
1000 1st Street N.W.
Suite 101
Fordland, Nubia 100001
Pursuant to Rule 101 of the Nubia Rules of Civil Procedure, Defendant, Hodown
Corporation (“Defendant”), through and by its counsel, Zhang, Wang & Lee, L.L.P.,
hereby requests that the Plaintiff, Sports Providers, Inc. (“Plaintiff” or “SPI”), provide
answers to the following interrogatories plainly, fully, in writing, and under oath.
The interrogatories are to be completed within thirty (30) days of their receipt and be
mailed to the offices of Zhang, Wang & Lee, L.L.P. at 666 East Chang’an Blvd., Beijing,
China 100001.
DEFINITIONS AND
INSTRUCTIONS
A. These interrogatories are continuing in character, so as to require you to file
supplementary answers if you obtain additional or different information
before trial.
B. Unless otherwise indicated, these interrogatories refer to the time, place
and circumstances of the occurrence mentioned or complained of in the
pleadings.
C. “Document” or “documents” shall mean, unless otherwise indicated, the
original copies of any written, typed, printed, photocopied, photographic or
tape recorded matter of any kind in your possession or known by you to
exist, no matter how produced, recorded, stored or reproduced including,
but not limited to, all letters, correspondence, books, periodicals, contracts,
telegrams, paper communications, tabulations, charts, memoranda,
handwritten notes, drafts, records, memoranda or transcriptions by a
mechanical device, by longhand or shorthand recording, tape recorder or by
any other means, inter-office communications, microfilms, lists, bulletins,
calendars, circulars, desk pads, ledgers, minutes, journals, diaries, invoices,
balance sheets, profit and loss statements, pamphlets, studies, notices,
summaries, reports, analyses, teletype messages, work sheets and all other
graphic materials, writings and instruments however produced or
reproduced. Said definition shall include, inter alia, recordings, transcripts
and/or summaries of oral communications, telephonic or otherwise.
D. The phrase “all documents” shall mean each and every document within a
stated category, known to you and/or documents reasonably subject to
identification, and/or documents that can be located on premises owned by
you and elsewhere. Documents located on premises other than your own
are specifically included.
E. “You” or “your” means Sports Providers, Incorporated, all its predecessors,
agencies and departments and their past and present subsidiaries and
parents; and all of its agents, servants and employees, and, unless privileged,
legal counsel.
F. The term “person” shall mean any individual, agency, department,
partnership, firm, corporation, association, joint venture, business, entity or
any employee or agent thereof.
G. “Date” shall mean the exact day, month and year, if ascertainable, or, if not,
the best approximation thereof.
H. The terms “identify” or “identification” and “describe” or “description”:
(i) When used in reference to an individual, shall mean to state his or
her full name, present or last known residence, home and business
telephone number, job title, present employer, and business address
(street, city and state);
(ii) When used in reference to a corporation, shall mean to state its full
name, its state of incorporation and its principal place of business;
(iii) When used in reference to a partnership, shall mean to state its full
name, the names of each partner and its principal place of business;
(iv) When used in reference to a person other than an individual,
corporation or partnership, shall mean to state its official name, its
organization form and its address;
(v) When used in reference to a government agency or department,
shall mean to state its full name and the names of each responsible
official and/or employee;
(vi) When used in reference to a document, shall mean to state the type
of document, date, author, addressee, title, serial or file number, its
present location, the name and address of its custodian and the
substance of the contents thereof. In lieu of identifying any
document, copies thereof may be furnished; andbalance sheets, profit and loss statements, pamphlets, studies, notices,
summaries, reports, analyses, teletype messages, work sheets and all other
graphic materials, writings and instruments however produced or
reproduced. Said definition shall include, inter alia, recordings, transcripts
and/or summaries of oral communications, telephonic or otherwise.
D. The phrase “all documents” shall mean each and every document within a
stated category, known to you and/or documents reasonably subject to
identification, and/or documents that can be located on premises owned by
you and elsewhere. Documents located on premises other than your own
are specifically included.
E. “You” or “your” means Sports Providers, Incorporated, all its predecessors,
agencies and departments and their past and present subsidiaries and
parents; and all of its agents, servants and employees, and, unless privileged,
legal counsel.
F. The term “person” shall mean any individual, agency, department,
partnership, firm, corporation, association, joint venture, business, entity or
any employee or agent thereof.
G. “Date” shall mean the exact day, month and year, if ascertainable, or, if not,
the best approximation thereof.
H. The terms “identify” or “identification” and “describe” or “description”:
(i) When used in reference to an individual, shall mean to state his or
her full name, present or last known residence, home and business
telephone number, job title, present employer, and business address
(street, city and state);
(ii) When used in reference to a corporation, shall mean to state its full
name, its state of incorporation and its principal place of business;
(iii) When used in reference to a partnership, shall mean to state its full
name, the names of each partner and its principal place of business;
(iv) When used in reference to a person other than an individual,
corporation or partnership, shall mean to state its official name, its
organization form and its address;
(v) When used in reference to a government agency or department,
shall mean to state its full name and the names of each responsible
official and/or employee;
(vi) When used in reference to a document, shall mean to state the type
of document, date, author, addressee, title, serial or file number, its
present location, the name and address of its custodian and the
substance of the contents thereof. In lieu of identifying any
document, copies thereof may be furnished; andbalance sheets, profit and loss statements, pamphlets, studies, notices,
summaries, reports, analyses, teletype messages, work sheets and all other
graphic materials, writings and instruments however produced or
reproduced. Said definition shall include, inter alia, recordings, transcripts
and/or summaries of oral communications, telephonic or otherwise.
D. The phrase “all documents” shall mean each and every document within a
stated category, known to you and/or documents reasonably subject to
identification, and/or documents that can be located on premises owned by
you and elsewhere. Documents located on premises other than your own
are specifically included.
E. “You” or “your” means Sports Providers, Incorporated, all its predecessors,
agencies and departments and their past and present subsidiaries and
parents; and all of its agents, servants and employees, and, unless privileged,
legal counsel.
F. The term “person” shall mean any individual, agency, department,
partnership, firm, corporation, association, joint venture, business, entity or
any employee or agent thereof.
G. “Date” shall mean the exact day, month and year, if ascertainable, or, if not,
the best approximation thereof.
H. The terms “identify” or “identification” and “describe” or “description”:
(i) When used in reference to an individual, shall mean to state his or
her full name, present or last known residence, home and business
telephone number, job title, present employer, and business address
(street, city and state);
(ii) When used in reference to a corporation, shall mean to state its full
name, its state of incorporation and its principal place of business;
(iii) When used in reference to a partnership, shall mean to state its full
name, the names of each partner and its principal place of business;
(iv) When used in reference to a person other than an individual,
corporation or partnership, shall mean to state its official name, its
organization form and its address;
(v) When used in reference to a government agency or department,
shall mean to state its full name and the names of each responsible
official and/or employee;
(vi) When used in reference to a document, shall mean to state the type
of document, date, author, addressee, title, serial or file number, its
present location, the name and address of its custodian and the
substance of the contents thereof. In lieu of identifying any
document, copies thereof may be furnished; and(vii) When used in reference to any act or occurrence, occasion, meeting,
oral communication, discussion, transaction or conduct, shall mean
to set forth the event or events constituting such act, its location, the
date and persons participating, present or involved, and the
documents relating or referring in any way thereto.
I. If you claim any form of privilege, whether based on a statute or otherwise,
as a ground for not answering an interrogatory or any portion thereof, set
forth in complete detail each and every fact upon which the privilege is
based, including sufficient facts for the court to make a full determination
whether the claim of privilege is valid.
Interrogatory No. 1: Please state the name, address, title and telephone
number of each of the officers and directors of SPI, along with a description of
their respective duties, responsibilities or contributions, in regard to the
operation and management of the business.
Interrogatory No. 2: Please identify any and all investigators, witnesses,
inspectors or informants who were present at any time at 200 Mt. Sad Street
N.W., Fordland City, Nubia, on January 15, 2005. For each investigator state: 1)
his/her name; 2) address; 3) identification number; 4) who they were working for;
5) how much they were paid; 6) who paid them; 7) to whom they reported; and 8)
during what hours they were on the premises.
Interrogatory No. 3: Identify by name, address and telephone number any
patrons, employees or other individuals with whom an investigator spoke in
regard to the matter in controversy and describe the substance of those
conversations.
Interrogatory No. 4: Please state the fees and costs, in U.S. dollars, that Hodown
Corporation would have been charged by SPI to exhibit the Ali v. Foreman fight
on January 15, 2005 at 200 Mt. Sad Street N.W., Fordland City, Nubia.
Interrogatory No. 5: Please state the amount, in U.S. dollars, that SPI paid to
purchase the distribution or sales rights for the Ali v. Foreman fight on January
15, 2005, for Nubia and the country to whom those amounts were paid.
Interrogatory No. 6: Please state the total number of commercial
establishments in the Fordland metropolitan area that purchased from SPI the
right to exhibit the Ali v. Foreman fight on January 15, 2005, and the gross
amount of revenue, in U.S. dollars, generated by such sales.
Interrogatory No. 7: Please list, by name and address, each commercial
establishment in the Fordland metropolitan area that purchased from SPI the
rights to exhibit the Ali v. Foreman fight on January 15, 2005.
Interrogatory No. 8: Prior to January 15, 2005, had any investigator, inspector or
any other agent or employee of SPI visited 200 Mt. Sad Street N.W., Fordland City,
Nubia for any reason? If yes, please identify that person by name, address and
identification number and describe the facts and circumstances surrounding that
visit including the date, time and the purpose.
Interrogatory No. 9: State the amount, in U.S. dollars, of SPI’s actual monetary
loss as a result of Defendant’s alleged exhibition of the Ali v. Foreman fight on
January 15, 2005.
Interrogatory No. 10: State the number of similar lawsuits filed by SPI in the past
four years throughout Nubia, the jurisdictions in which they were filed, the
names and addresses of the defendants and the outcomes.
Interrogatory No. 11: Identify each person you presently expect to call as a
witness at trial, and for each person, state:
a. The subject matter on which said witness is expected to testify; and
b. The substance of the facts and opinions to which the witness is
expected to testify.
Interrogatory No. 12: Identify all persons who participated in the preparation of
the answers to these interrogatories, specifying which person participated in the
preparation of which answer.
Dated: May 18, 2006
Respectfully submitted,
Zhang, Wang & Lee, L.L.P.
______________________
Deguang Zhang
Attorneys for Defendant
666 East Chang’an Blvd.
Beijing, P.R.China 100001
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