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
(聲明:本站所使用圖片及文章如無注明本站原創(chuàng)均為網(wǎng)上轉(zhuǎn)載而來,本站刊載內(nèi)容以共享和研究為目的,如對(duì)刊載內(nèi)容有異議,請(qǐng)聯(lián)系本站站長(zhǎng)。本站文章標(biāo)有原創(chuàng)文章字樣或者署名本站律師姓名者,轉(zhuǎn)載時(shí)請(qǐng)務(wù)必注明出處和作者,否則將追究其法律責(zé)任。) |