DEFENDANT, UNICCO SERVICE COMPANY’S, NOTICE OF FILING STANDARD INTERROGATORIES TO

PLAINTIFF JUANA CONTRERAS

The plaintiff, Juana Contreras, is hereby requested to respond to the following discovery:

1. Standard interrogatories within the time allowed by….

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been furnished via U. S. mail on
June 11, 2010 to Norman Funt, Esq., Stabinski & Funt, ……

INTERROGATORIES TO PLAINTIFF, JUANA CONTRERAS

1. What is the name and address of the person answering these interrogatories, and, if
applicable, the person’s official position or relationship with the party to whom the
interrogatories are directed

2. Who is your cell phone provider carrier, and cell phone number

3. List the names, business address, dates of employment and rates of pay regarding all
employers, including self employment for whom you worked in the past ten years

4. List all former names and when you were known by those names. State all address where
you have lived for the past ten years, the dates you lived at each address, your social
security number, your date of birth, and if you are or have been married, the name of your
spouse or spouses.

5. Do you wear glasses, contact lenses or hearing aids if so, who prescribed them when were
they prescribed when were your eyes or ears last examined and what is the name and
address of the examiner

6. Have you ever been convicted of a crime, other than any juvenile adjudication, which
under the law under which you were convicted was punishable by death or imprisonment
in excess of one year, or that involved dishonesty or a false statement regardless of the
punishment if so, state as to each conviction, the specific crime, the date and the place of
conviction.
7. Were you suffering from infirmity, disability, or sickness at the time of the incident
described in the complaint if so, what was the nature of the infirmity, disability or sickness

8. Do you consume any alcoholic beverages or take any drugs or medication within twelve
hours before the time of the incident described in the complaint? If so, state the type and
amount of alcoholic beverages, drugs or medication which ere consumed and when and
where you consumed them.

9. State where and when the alleged incident occurred, giving the date, hour and minute as
nearly as possible and describing as fully as possible the location of the alleged incident
giving in your answer the distance to fixed objects or boundaries by which the location
may be identified.

10. State the reason that you were on the premises where the incident alleged in the
complaint occurred, setting forth specifically whether you were there on business or
otherwise and whether you had permission or were invited to be on said premises.

11. Describe in chronological detail how the alleged accident occurred, stating everything that
happened from the time a few minutes immediately preceding the alleged incident to and
including the time of the alleged accident.

12. Describe with the particularity the alleged defect, defective condition, substance or object
which caused the alleged occurrence, giving all exact dimensions or other physical
characteristics of the alleged defect, condition, substance or object and its immediate
vicinity

13. Did you have any knowledge of the existence of the alleged defect, defective condition,
substance or object prior to your alleged incident?

a. If so, how did you acquire such knowledge and how long did you know that the alleged
defective condition, substance or object had existed prior to your alleged occurrence.
14. Describe in detail, each act or omission on the part of the defendant you contend
constituted negligence that caused or was a contributing legal cause of the accident in
question.
15. List the names and addresses of all witnesses who are known by you, your agents or
attorneys to have any knowledge concerning the fall alleged by you in this cause.
16. As you approached the location where the alleged incident occurred, did you see any
warnings signs or devices of any kind or did the defendant give any warning or signal,
either written or oral? Describe any such warnings signs or devices or warning or signal
given by the defendant in complete detail.
17. Describe each injury for which you are claiming damages in this case, specifying the part of
your body that was injured, the nature of the injury, and, as to any injuries you contend
are permanent, the effects on you that you claim permanent.
18. With respect to any injuries or symptoms described in your answer to interrogatory No.
16, please state whether you, at any other time, ever had any similar injury to or similar
symptom of the same or similar area of your body involved, the date and duration of such
injury or symptom, and the names and address of any physician or hospitals that thread
you for such injury or symptom.
19. List each item of expense or damage, other than loss of income or earning capacity, that
you claim to have incurred as a result of the incident described in the complaint, giving for
each item the date incurred, the name and business address to whom each was paid or is
owed, and the goods or services for which each was incurred.
20. Do you contend that you have lost any income, benefits, or earning capacity in the past or
future as a result of the incident described in the complaint? If so, state the nature of the
income, benefits, or earning capacity, and the amount and the method that you used in
computing the amount.
21. Has anything been paid or is anything payable from any third party for the damages listed
in your answers to these interrogatories? If so, state the amounts paid or payable, the
name and business address of the person or entity who paid or owes said amounts, and
which of those third parties have or claim a right of subrogation.
22. List the names and business address of each physician who has treated or examined you,
and each medical facility where you have received any treatment or examination for the
injuries for which you seek damages in this case, and state as to each the date of
treatment or examination and the injury or condition for which you were examined or
treated.
23. List the names and business addresses of all other physicians, medical facilities or other
health care providers by whom or at which you have been examined or treated in the past
ten years, and state as to each the dates of examination or treatment and the condition or
injury for which you were examined or treated.
24. List the names and addresses of all persons who are believed or known by you, your
agents or attorneys to have any knowledge concerning any of the issues in this lawsuit,
and specify the subject matter about which the witness has knowledge
25. Have you heard or do you know about any statement or remark made by or on behalf of
any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so,
state the name and address of each person who made the statement or statements, the
name and address of each person who heard it, and the date, time, place and substance of
each statement.
26. Do you intend to call any expert witnesses at the trial of the case? If so, state as to each
such witness the name and business address, the witness’s qualifications and an expert,
the subject matter upon which the witness is expected to testify, and a summary of the
grounds for each opinion.
27. Have you made an agreement with anyone that would limit that party’s liability to anyone
for any of the damages sued upon in this case? If so, state the terms of the agreement and
the parties to it.
28. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
than the present matter and if so, state whether you were plaintiff or defendant, the
nature of the action, and the date and court in which such suit was filed. Please include
any workers compensation claims or disputes in your answer.
29. Please state whether you have been involved in any other accidents or incidents, either
preceding or subsequent to the subject accident, if so, please provide the date of any such
accident or incident, the circumstances surrounding said event, describe any injuries you
may have suffered and provide the names, dates and addresses or health care providers
who treated or examined any such injuries. Please state every accident or incident,
whether or not you suffered any injury.
30. Please state the name, business address, resident address, business telephone number
and residence telephone number of the person who took any and all photographs
concerning the incident or injuries complained of in plaintiff’s complaint and state for each
person, the date upon which the photographs were taken, the number of photographs
taken at the same location and or on the same day relative to the incident complained of
in the plaintiff’s complaint and the name, business address, residence address, business
telephone number and residence telephone number of all persons present said
photographs were taken.
31. State whether or not you have been involved in any accidents or incidents resulting in
personal injury prior to or after the incident described in the complaint and if so, state the
place of each said accident or incident, the date of each said accident or incident, any
personal injuries that you may have received in any such accident or incident, the name of
each and every medical practitioner treating you or examining you for each of the said
injuries.
32. Have you ever received an disability rating of any type whatsoever from any individual or
private governmental organization before or after the incident described in the complaint
and not related to the incident described in the complaint and if so, state as to each the
name and address of the physician or organization giving such rating, the date of the
rating, the amount of the disability rating, and describe the nature of the incident causing
the disability rating.
33. Please indicate whether or not there are any activities you were able to do prior to this
incident but are no longer able to do, as a result of injuries which you sustained in this
accident. If so, please indicate the nature of the activity and the reason you are unable to
perform it.
34. Please list the names and addresses of any gym or workout club memberships affiliations
you have been a member of in the last 5 years.
35. Please list any physical hobbies or recreational activities you have been involved with in
the past five years (example bowling basketball, softball. Etc)
36. Please state any and all health insurance, HMO coverage, or any other type of health care
plan you have had for the past ten years, stating the name of the company, the address,
the type of coverage, the policy number, group health number, the name of the insured
and all insureds under said policy, and any other information contained on any cards
provided to you with such coverage.