Template:Boilerplate Legal Text: SvsG Document Discovery 1

1. List each item of merchandise which belongs to Plaintiff Red House Media, which is currently in your possession or control. If these items are no longer in your possession, state whether or not they have been sold.
2. If the items described in Interrogatory No. 1 have been sold, provide the name, address and telephone number of the persons or entities to which they were sold, and the price and date of each sale.
3. Identify all persons with personal knowledge of business relationships between you and Plaintiffs.
4. Please state the full name, address and telephone number of every person whom you believe to have any relevant knowledge whatsoever concerning the facts and issues in the above-styled case.
5. Please list and describe in detail each and every document, photograph, memorandum, paper, tape recording or other items of physical or material evidence which you may use or have available for public use at the trial of the above-styled case.
6. If tape-recorded statements or any form of written memoranda of the contents of the aforestated persons' interviews were obtained, please describe in detail the nature of said statements, recordings or memoranda, and give the full names, addresses and telephone numbers of any person or persons who have custody, possession, or control of said statements, recordings or memoranda.
7. Identify each person whom you expect to call as an expert witness at trial and state:
   • (a) The subject matter on which said expert is expected to testify;
   • (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion;
   • (c) The address, telephone number, education and training of said expert.
8. If there exists any insurance agreement of any type whatsoever under which any person carrying on an insurance business may be liable to satisfy part or all of a judgement which may be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment, state as to all such agreements:
   • (a) The name of the insurer;
   • (b) The name of the insured;
   • (c) The type of insurance;
   • (d) The date such agreement was made;
   • (e) The policy or other identifying number;
   • (f) The amount of the insurer's potential coverage under the agreement; and
   • (g) Any conditions on such agreement which you believe may negate or limit the insurer's liability in this case.
9. State all facts concerning any instance where you have ever been arrested or convicted or any crime.
10. State all facts concerning any legal proceedings (including claims for workers' compensation) in which you or any member of your immediate family have ever been a party and identify the courts and parties involved.