One part of the process of consumer litigation, which is called written discovery, is the exchanging of interrogatories. These are sent to narrow the issues and establish the claim made by the plaintiff.
1. Why did the defendant collect the following from the plaintiff?:
a. Destination and delivery b. Used vehicle preparation c. Credit Bureau Inquiry d. Online Registration e. Data Processing fee f. Administration Fee
2. If this is answered “not relevant” please explain why it is not relevant.
3. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
4. What actions did the defendant perform while collection money for the following?:
a. Destination and delivery b. Used vehicle preparation c. Credit Bureau Inquiry d. Online Registration e. Data Processing fee f. Administration Fee
5. If this is answered “not relevant” please explain why it is not relevant.
6. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
7. Was any money collected for the following paid to any third parties? If so, how much?
a. Destination and delivery b. Used vehicle preparation c. Credit Bureau Inquiry d. Online Registration e. Data Processing fee f. Administration Fee
7. If this is answered “not relevant” please explain why it is not relevant.
9. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
10. Why did the defendants charge the plaintiff a destination and delivery while also charging the plaintiff for used car preparation?
11. If this is answered “not relevant” please explain why it is not relevant.
12. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
13. Would the defendant describe the following as predelivery services? If not. explain each answer.
a. Destination and delivery b. Used vehicle preparation c. Credit Bureau Inquiry d. Online Registration e. Data Processing fee f. Administration Fee
14. If this is answered “not relevant” please explain why it is not relevant.
15. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
16. How many used cars did the defendant sell in calendar years 2002-2006?
I17. If this is answered “not relevant” please explain why it is not relevant.
18. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
19. How many new cars did the defendant sell in calendar years 2002-2006?
20. If this is answered “not relevant” please explain why it is not relevant.
21. If this question is answered “it is too burdensome” please explain why it would be too burdensome.
22. Were the following charged to used cars, new cars or both during the alleged class period?
a. Destination and delivery b. Used vehicle preparation c. Credit Bureau Inquiry d. Online Registration e. Data Processing fee f. Administration Fee
23. If this is answered “not relevant” please explain why it is not relevant.