RESPONSE TO PLAINTIFFS FORMINTERROGATORIES – EMPLOYMENTLAW

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Samples legal papers
March 16, 2023

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    RESPONSE TO PLAINTIFF’S FORM INTERROGATORIES – EMPLOYMENT LAW SET ONE   

PROPOUNDING PARTY: Plaintiff ALEXANDER TRON

RESPONDING PARTY: Defendant RONALD GOODSON

SET NUMBER: ONE

Responding to this discovery under the superior court caption is not intended to act as a
waiver of Defendant’s right to assert binding arbitration in this matter. These responses are made solely for the purpose of this action. Each answer is subject to all objections as to competence, relevance, materiality, propriety and admissibility, and any and all other objections on grounds that would require the exclusion of any statement contained herein in any Interrogatories were asked of, or any statement contained herein were made by, a witness present and testifying in Court, all of which objections and grounds are reserved and may be interposed at the time of trial.
Except for explicit facts admitted herein, no incidental or implied admissions are
intended hereby. The fact that defendant has answered or objected to any Interrogatory or any part thereof should not be taken as an admission that she accepts or admits the existence of any facts set forth or assumed by such Interrogatory or that such answer or objection constitutes admissible evidence. The fact that defendant has not answered part or all of any Interrogatory is not intended and shall not be construed to be a waiver by her of all or any part of any objection to any Interrogatory propounded by plaintiffs.

To the extent any or all of the Interrogatories call for information which constitutes
information or material prepared in anticipation of litigation or for trial or information or material covered by the work product doctrine or which constitutes information which is privileged by virtue of the attorney-client privilege, this defendant objects to each and every such Interrogatory and thus will not supply or render any information or material protected from discovery by virtue of the work product doctrine or attorney-client privilege.

Defendant has not completed the investigation of the facts relating to this case, has not completed discovery of this action, and has not completed preparation for trial. The following answers are given without prejudice to the production of subsequently discovered facts or evidence, or the presentation of facts or theories resulting from subsequently discovered evidence, re-evaluation of the existing evidence, or evaluation of existing evidence in light of newly discovered evidence

RESPONSE No. 200.1:

  1. Yes

RESPONSE No. 200.2:

  • No

RESPONSE No. 200.3:

  • Yes. There was an implied fairness and good dealing agreement

RESPONSE No. 200.4

  • The general state of California

RESPONSE No. 200.5

  • No.

RESPONSE No. 200.6

  • No.

RESPONSE No. 201.1

  • No.

RESPONSE No. 201.2

  • The employee had been calling in sick repeatedly missing shifts that Plaintiff Alexander Tron was scheduled to work. I was aware he was leaving the country and he intended to terminate his employment. He said he was going to pursue studies at law school. Having such knowledge, I offered to settle with him and misconstrued my offer as a termination and immediately placed a demand for payment of $4000 – $5000 for unpaid overtime and meal breaks.

RESPONSE No. 201.3

  • Yes, Plaintiff Alexander Tron would on various occasions give short notice. He gave two weeks notice for an appointment, which nature of the appointment was never indicated. Plaintiff would later retroactively demand for sick pay for the aforementioned vague appointment.

RESPONSE No. 201.4

  1. Plaintiff Alexander Tron was never terminated. He was only offered an opportunity to settle up to avoid him calling in sick when the business was desperate to have drivers.

RESPONSE No. 201.5

  1. Unable to ascertain as we were constantly short handed in every department.

RESPONSE No. 201.6

  1. Yes.
  2. Megan Wahl.
  3. 6033 La Cumbra Road. Somis, CA. 93066
  4. Plaintiff Alexander Tron left her a video tutorial on how to perform his responsibilities
  5. Jessee. A remote computer technician whom Plaintiff Alexander Tron had been working with. Jessee took up some of the duties of Plaintiff Alexander Tron.

RESPONSE No. 201.7

  1. Plaintiff Alexander Tron Willingly quit. Offer to settle was made, which Plaintiff Alexander Tron misinterpreted as termination and demanded payment of $4000-$5000. He later left the country to pursue studies.

RESPONSE No. 204.3

  1. No.

RESPONSE No. 204.4:

  1. No.

RESPONSE No. 204.6

  • No.

RESPONSE No. 204.7

  • I offered to settle up with Alexander Tron and he sanded a much higher amount of money that what was owed

RESPONSE No. 207.1

  • No.

RESPONSE No. 207.2

  • No. At the last minute after I had made an offer to settle up, Plaintiff Alexander Tron submitted a large bill which had mathematical and computational errors.

RESPONSE No. 208.1

  • Yes. With the Labour Relations Board

RESPONSE No. 208.2

  • Matter still pending hearing. The same has been delayed for one year and nine months.

RESPONSE No. 209.2:

  • Yes.
  • Alex Smith filed a civil action. His address is 18319 Heart Street no. 16 Reseda, CA 91335.
  • Filed actuon for unlawful termination. However the same was no call/no show for three days straight.
  • Joe Brulia. Claim in small claims court. The same was determined iny favour. He later filed an action in the labour relations court, which matter was settled satisfactorily.

RESPONSE No. 211.1

  • None.

RESPONSE No. 211.2:

  • Yes.
  • potential conspiracy to defraud
  • potential fraud by Alexander Tron time clock entries
  • notice is too short to avail further information

RESPONSE No. 211.3

  • Yes
  • The entire amount is disputed
  • Plaintiff Alexander Tron terminated his employment to pursue studies in Europe.

RESPONSE No. 214.1

  1.  yes
  2. We had proper workers compensation insurance. We had business liability insurance. Automobile liability insurance.
  3. Not aware of any clause covering this employment action. Policy was eventually cancelled.

RESPONSE No. 214.2

  • No.

RESPONSE No. 215.1

  • No.

RESPONSE No. 215.2

  • No.

RESPONSE No. 216.1

  • Yes. My affirmative defense is suspicion of time clock fraud occasioned by Plaintiff Alexander Tron. Precisely, 148 instances of manual time clock overrode with Plaintiff’s login credentials.

RESPONSE No. 217.1:

  • No admissions..

Dated: _________________

BY: ____________________

RONALD  GOODSON

Defendant

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