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1 Edward C. Rickstang (SBN RICHMOND & FIELDS LLP S. Rawlston Avenue Suite 0 Altford, CA 01 Tel: ( 0- Fax: ( 0- Attorneys for Plaintiff HEALTHBILL SYSTEMS, LLC UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA HEALTHBILL SYSTEMS, LLC, v. Plaintiff, CHAD SRINIKRISH, LAWRENCE LEVITISAN, OPTIMUM TECHNOLOGY SOLUTIONS PVT. LTD., AND OPTIMUM TECHNOLOGY SOLUTIONS, LLC, Defendants. Case No. :0-cv-0-VSP (BRL PLAINTIFF HEALTHBILL SYSTEMS, LLC S SPECIAL INTERROGATORIES (SET ONE TO DEFENDANT LAWRENCE LEVITISAN PROPOUNDING PARTY: Plaintiff HEALTHBILL SYSTEMS, LLC RESPONDING PARTY: Defendant SET NUMBER: ONE (1-1 - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
2 Plaintiff, HEALTHBILL SYSTEMS, LLC, ( Plaintiff or Healthbill, hereby propounds the following Special Interrogatories to be answered by Defendant ( Defendant under oath, within thirty (0 days after service hereof pursuant to Federal Rules of Civil Procedure, Rule. DEFINITIONS AND INSTRUCTIONS The Plaintiff hereby incorporates the definitions set forth in the Federal Rules of Civil Procedure and Local Rules. Additionally, the following definitions apply for purposes of responding to these interrogatories: (1 Communication. The term communication means the transmittal of information (in the form of facts, ideas, inquiries or otherwise and includes but is not limited face-to-face interaction, phone calls, mail, and exchanges. ( Document. The term document is defined to include writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations stored in any medium from which information can be obtained translated, if necessary, by the respondent into reasonably usable form. A draft or nonidentical copy is a separate document within the meaning of this term. The term document shall encompass and includes electronically stored information (ESI. ( Electronically stored information. The term electronically stored information (ESI should be afforded the broadest possible definition. Generally, it is defined as information stored by digital, electrostatic, electromagnetic, optical, or other electronic means, including that located or stored on or in computer(s, server(s, disk(s, drive(s, cellular phone(s, PDA(s, smartphone(s, database(s, and/or any other electronic medium from which information can be stored or obtained. By way of example but not limitation, some common forms of electronically stored information are s, text messages, word-processing documents, spreadsheets, data files, instant messages, voiceover internet protocol messages, random access memory, memory, folders, files, audio recordings, video recordings, read-only files, text files, archived files, backup files and tapes, images, CRM data such as Outlook, calendar and application data, and/or other - - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
3 communications, documents, or data. This definition includes all meta data or other identifiers associated with all ESI. This definition includes the native format of all ESI. ( Identify (With Respect to Persons. When referring to a person, to identify means to provide, to the extent known, the person s full name, present or last known address, and when referring to a natural person, additionally, the present or last known place of employment. Once a person has been identified in accordance with this subparagraph, only the name of that person need be listed in response to subsequent discovery requesting the identification of that person. ( Identify (With Respect to Documents or ESI. When referring to documents or electronically stored information, to identify means to provide, to the extent known, information about the (i type of document or ESI; (ii its general subject matter; (iii the date of the document or ESI creation; and (iv author(s, addressee(s and recipient(s; whether the ESI exists in native form; (iv whether meta data exists and has been preserved for all ESI. ( Defendants. The term Defendants refers to the named Defendants, individually and collectively. ( You/Your. The terms you/your refer to Defendant or Defendants, their employees, servants, agents, representatives, affiliates, or persons otherwise acting for Defendant or Defendants on their behalf in any capacity, but specifically excludes any attorneys retained by Defendants in connection with this lawsuit to the extent that their inclusion within the definition of the foregoing terms would render an interrogatory or request for production hereunder an invasion of the attorney/client privilege. ( All/Each. The terms all and each shall both be construed as all and each. ( And/Or. The connectives and and or shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside its scope. - - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
4 INTERROGATORIES 1. Identify all sources where ESI may reside in your possession, custody or control that concern or relate to Plaintiff or Argent including ESI that is readily accessible and inaccessible.. Identify all electronic devices including, but not limited to, desk top computers, lap top computers, personal digital assistants, smart phones, and cell phones used by you for business use from October to the present date including the make, model, phone number, all addresses associated with each device and all contents thereon.. Identify all personal and business tax returns filed by you from October to the present date.. Identify the following dates: a. You first made any efforts to assist with the formation of Optimum or OPTIMUM. b. You first made any efforts to assist with the operation of Optimum or OPTIMUM. - - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
5 c. You first made any efforts to solicit customers or prospects for Optimum or OPTIMUM.. Identify any and all of your current or former customers that were former customers or prospects of Healthbill to include name of the customer, address of the customer, sales person handling the customer and the contact person at customer.. Identify each current or former Healthbill customer or prospect of Healthbill that you have contacted or solicited while employed by Healthbill or Argent that is now your current or former customer and include name of the customer, address of the customer, sales person handling the customer for Defendants, and the contact person at customer.. Describe in detail all of your internal business procedures and components used to manufacture your products. - - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
6 . What is the best method for determining the tensile strength of the products at issue in this litigation, factoring in friction viscosity?. What steps did you undertake to ensure that the incident which is at issue in this litigation did not repeat itself?. State all advice provided to you by your attorney prior to your February th deposition in this litigation.. Identify in detail all purchases your company has made since.. Explain why you believe it is a good idea to steal from your employers. - - PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
7 . Identify all machinery that you believe is covered by the contract.. The following interrogatory requires you to provide your answer entirely in German and mail it to Plaintiff as a separate document: Identify the method by which you process a customer complaint.. What were your favorite hobbies as a child and why? DATED: July, - - RICHMOND & FIELDS LLP By: Edward C. Rickstang Attorneys for Plaintiff Healthbill Systems, LLC PLAINTIFF HEALTHBILL SYSTEMS, LLC S INTERROGATORIES (SET ONE TO DEFENDANT
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