1. Please list the individual answering these interrogatories and all the investigations you have undertaken, all the documents you have reviewed and individuals you have spoken to prior to answering these interrogatories.
2. Please list each and every individual with whom the plaintiff spoke to or dealt with in the process of acquiring the subject automobile. Please list the specific person, their first and last name, the specific date of the conversation, the nature of the conversation and all witnesses to this conversation.
3. Please list the specific individuals who were responsible for, participated in or in any ways they perform were present during the installation of the ‘ResistAll Enviroguard’ product. Please specify the specific time, date and place in which this was placed on the plaintiff’s vehicle. Please set forth the process by which this product was applied to the plaintiff’s vehicle. Please set forth the individuals who applied this product to the plaintiff’s vehicle. Please attach any and all documentation supporting the fact that this product was applied to the plaintiff’s vehicle.
4. Please list the specific time, date and place in which any money was forwarded to Cal-Tex Protective Coatings, Inc. for the purchase of the ResistAll Enviroguard product. Please set forth time, date and place of this communication and the amount of money sent to Cal-Tex Protective Coatings, Inc.
5. At any time during or after the transaction, did the plaintiff pay for ‘PDSI’? If so, please set forth the amount. What exactly is PDSI and what is the reason the plaintiff paid for same?
6. How much did the plaintiff pay for ‘ORGFEE’? Please specific why it was in this specific amount and why it was charged.
7. At any time, did the plaintiff acquire ‘tire/wheel’ product? If so, please set forth the amount paid by the plaintiff. Indicate when and how much money was sent to the supplier of this product, Auto Knight Motor Club. Please attach any and all documentation supporting transmission of the money.
8. Please describe any and all documents in which the plaintiff specifically signed indicating/acknowledging purchase of window etch, PDSI, ORGFEE and tire or wheel. Please set forth the individuals of the dealership who witnessed the plaintiff signing this documentation.
9. Did the defendant, their agents, servants and/or employees ever advertise in any ways they perform the subject automobile purchased by the plaintiffs? If so, please set forth the time of any and all TV advertisements, nature and extent of any newspaper advertisements.
10. If the price of the vehicle was sold in excess of the advertised price, please set forth the reasons why.
11. Please attach a copy of your applicable insurance coverage for this claim.
12. Please attach copy of any documents signed by the plaintiff.
13. Please attach copy of the entire deal jacket.
14. Please explain if the plaintiff paid a destination charge. If so, please set forth why the plaintiff paid a destination charge.
15. Please explain why the PDSI, origination fee, tire and wheel and destination charges were not included on the retail installment sales contract.
16. Please list any and all pre-delivery services or after-market items purchased by the plaintiff.
Updated: