RONALD GOODSON

2212 Via Lorna,

Camarillo, CA. 93012

Phone Number (805) 754 5371

Email Address tonysnypizzeria31@gmail.com

In Pro Per

SUPERIOR COURT OF CALIFORNIA
IN AND FOR THE COUNTY OF VENTURA

ALEXANDER TRON, an individual  Plaintiff,  vs.  RONALD GOODSON, individually and d/b/a TONY’S NY PIZZERIA, TONY’S PIZZA BRO’S, a California LLC,  DOES 1 through 10, inclusive,  Defendants. ))))))))))))))))))) Case No.: 56-2021-00552590-CU-WT-VTA    DEFENDANT’S SPECIAL INTERROGATORIES SET ONE   

PROPOUNDING PARTY: Defendant RONALD GOODSON 

RESPONDING PARTY: Plaintiff ALEXANDER TRON

SET NUMBER: ONE

Defendant, Ronald Goodson, requests that Plaintiff, Alexander Tron, respond to the following special interrogatories separately and fully in writing and under oath, pursuant to Section 2030.010 et seq. of the Code of Civil Procedure, and that the response be signed by the person making them and be served on Defendant, Paul Sample within 30 days (35 days if these Interrogatories were served by mail within California) from the date of service.

In answering these interrogatories, furnish all information that is available to you. If you cannot answer an interrogatory completely, answer it to the extent possible. If you do not have personal knowledge sufficient to respond fully to an interrogatory, so state, but make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, unless the information is equally available to the propounding party.  DEFINITIONS

  1. “PLAINTIFF,” “YOU” and “YOUR” shall   mean   PLAINTIFF Alexander Tron.
  2. “DEFENDANT” shall mean DEFENDANT Ronald Goodson.
  3. “INCIDENT” means and refers to the incident described in PLAINTIFF’s Complaint upon which this suit is founded.

SPECIAL INTERROGATORY NO. 1:

What role did you take up at the time of your employment with the Defendant?

SPECIAL INTERROGATORY NO. 2:

Are you aware of the time card system used by all employees during your employment?

SPECIAL INTERROGATORY NO. 3:

Were you ever been appointed by your superior to oversee the time card system? If so, state the name of the person and the position they held at the time of your employment.

SPECIAL INTERROGATORY NO. 4:

Have you ever interacted with the time card system without the express authority of your superiors? If so, state the nature of the interaction.

SPECIAL INTERROGATORY NO. 5:

At the time of the incident, were you informed of any ongoing manipulation of the time card system? If so state, by whom were you informed?

SPECIAL INTERROGATORY NO. 6:

At the time of the incident, did you, or someone on your behalf, manipulate the time card system? If so, give the names of all the persons involved.

SPECIAL INTERROGATORY NO. 7:

At the time of the incident, describe whether your time card had been manipulated to represent false information. If so, describe the false information.

 SPECIAL INTERROGATORY NO. 8:

At the time of the incident, were you aware that your time card contained false information?

SPECIAL INTERROGATORY NO. 9:

At the time of the incident, did you admit to willingly manipulating the time card system? If so, to whom did you admit?

Dated: _________________

BY: ____________________

RONALD  GOODSON

Defendant

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