RESPONSE TO PLAINTIFFS FORMINTERROGATORIES

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Samples legal papers
March 29, 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 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 TO INTERROGATORY NO. 1:

  1. Name: Ronald Goodson
  2. Address: 2212 Via Lorna, Camarillo, CA.  
  3. Phone: (805) 754 53711

RESPONSE TO INTERROGATORY NO. 2.1:

  • See No. 1

RESPONSE TO INTERROGATORY NO. 2.2:

  • Born in Santa Monica, CA

RESPONSE TO INTERROGATORY NO. 2.3

  • I had a driver license in California,
  • License number is C1468053,
  • Date of issuance is unknown.

RESPONSE TO INTERROGATORY NO. 2.4

  • I had a Permit to operate a motor vehicle.

RESPONSE TO INTERROGATORY NO. 2.5

  1. See No. 1

RESPONSE TO INTERROGATORY NO. 2.6

  1.  

RESPONSE TO INTERROGATORY NO. 2.7

  1. Irrelevant to the substance of this suit.

RESPONSE TO INTERROGATORY NO. 2.8

  1. No

RESPONSE TO INTERROGATORY NO. 2.9

  1. Yes

RESPONSE TO INTERROGATORY NO. 2.10

  1. Yes.

RESPONSE TO INTERROGATORY NO. 2.11

  1. Yes. I was acting as the employer of Alexander Tron.

RESPONSE TO INTERROGATORY NO. 2.12

  1. I am unable to determine if anyone had a disability.

RESPONSE TO INTERROGATORY NO. 2.13

  1. No.

RESPONSE TO INTERROGATORY NO. 3.1:

  1. No.

RESPONSE TO INTERROGATORY NO. 3.2

  • No.

RESPONSE TO INTERROGATORY NO. 3.3

  • No.

RESPONSE TO INTERROGATORY NO. 3.4

  • No.

RESPONSE TO INTERROGATORY NO. 3.5

  • No.

RESPONSE TO INTERROGATORY NO. 3.6

  • Yes. Tony’s NY Pizzeria

RESPONSE TO INTERROGATORY NO. 3.7

  • Yes. A license to operate sales of solar products.

RESPONSE TO INTERROGATORY NO. 4.1:

  • We had proper workers compensation insurance. We had proper liability insurance.
  • I have never read the policies.

RESPONSE TO INTERROGATORY NO. 4.2

  • I am not insured under any statute.

RESPONSE TO INTERROGATORY NO. 12.1:

  • Short notice. Unable to ascertain this information, if at all there is such a person.

RESPONSE TO INTERROGATORY NO. 12.2

  • No.

RESPONSE TO INTERROGATORY NO. 12.3

  •  No

RESPONSE TO INTERROGATORY NO. 12.4

  • No

RESPONSE TO INTERROGATORY NO. 12.5

  • No

RESPONSE TO INTERROGATORY NO. 12.6

  • No

RESPONSE TO INTERROGATORY NO. 12.7

  • No

RESPONSE TO INTERROGATORY NO. 13.1:

  • No

RESPONSE TO INTERROGATORY NO. 13.2

  • No. There is no surveillance

RESPONSE TO INTERROGATORY NO. 15.1:

  • See attached Answer to Complaint.

RESPONSE TO INTERROGATORY NO. 16.1:

  • No

RESPONSE TO INTERROGATORY NO. 16.2

  • See attached Answer to Complaint.

RESPONSE TO INTERROGATORY NO. 16.9

  • No.

RESPONSE TO INTERROGATORY NO. 17:

  •  

RESPONSE TO INTERROGATORY NO. 50.1:

  • It was an oral agreement.

RESPONSE TO INTERROGATORY NO. 50.2

  • There was a breach of the agreement due to alleged time card fraud
  • Breach occurred during Alexander Tron’s employment.

RESPONSE TO INTERROGATORY NO. 50.3

  • No

RESPONSE TO INTERROGATORY NO. 50.4

  • Unable to ascertain.

RESPONSE TO INTERROGATORY NO. 50.5

  • No.

RESPONSE TO INTERROGATORY NO. 50.6

  • No.

Dated: _________________

BY: ____________________

RONALD  GOODSON

        David Alomatsi, Plaintiff

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