Defendant's Contention Interrogatories To Plaintiff

1. Describe in detail what you contend the defendant did, or failed to do, that entitles you to the relief sought in the complaint.

2. Describe all regulations, laws, codes, customs, usages or standards that you contend are applicable to any claim or defense in the case.

3. Identify all witnesses to the events described in your complaint.

4. Identify each expert whom you intend to call as a witness at trial and with respect to each, include qualifications, the subject matter on which the expert is expected to testify, the substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds of each opinion. Additionally, attach a copy of the expert's curriculum vitae or resume.

5. If you contend that you have been injured as a result of the acts complained of, describe the injuries and damages and list the elements of damage that you contend you are entitled to recover and the methods by which you contend your damages should be computed.

6. Do you contend that...