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 – GENERAL 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:
- Yes
RESPONSE No. 200.2:
- See No. no
RESPONSE No. 200.3:
- Yes.
RESPONSE No. 200.4
RESPONSE No. 200.5
- No.
RESPONSE No. 200.6
- No.
RESPONSE No. 201.1
RESPONSE No. 201.2
RESPONSE No. 201.3
RESPONSE No. 201.4
RESPONSE No. 201.5
RESPONSE No. 201.6
RESPONSE No. 201.7
RESPONSE No. 204.3
RESPONSE No. 204.4:
RESPONSE No. 204.6
RESPONSE No. 204.7
RESPONSE No. 207.1
RESPONSE No. 207.2
- No.
RESPONSE No. 208.1
RESPONSE No. 208.2
RESPONSE No. 209.2:
RESPONSE No. 211.1
- Short notice.
RESPONSE No. 211.2:
- Yes.
- potential conspiracy to defraud
- potential fraud from Alexander Tron time clock entries
- notice is too short to avail further information
RESPONSE No. 211.3
- Yes
- The entire amount is disputed
- potential fraud from Alexander Tron time clock entries
RESPONSE No. 214.1
- yes
- We had proper workers compensation insurance. We had proper liability insurance.
RESPONSE No. 214.2
- No
RESPONSE No. 215.1
- No
RESPONSE No. 215.2
- No
RESPONSE No. 216.1
- See Answer to Complaint
RESPONSE No. 217.1:
- unable to determine as to the potential fraud from Alexander Tron time clock entries
Dated: _________________
BY: ____________________
RONALD GOODSON
Defendant
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