Interrogatories - Product Liability

[Plaintiff to Defendant]

1. State your full name, address, occupation, title, and relationship to the Defendant Corporation ____________, Inc., also, please provide the full name, address, occupation, title, and relationship to the Defendant of each individual who assisted in the answering of these interrogatories.

2. State the precise name, address, date of incorporation and state of incorporation for the Defendant __________, Inc. and describe in detail the business conducted by it from __________ through the date of your answers to these interrogatories.

3. State the relationship of the Defendant __________, Inc. with respect to the ___________________ [Brief Description of Product], which is the subject of this litigation (hereafter referred to only as “Product”); in particular, is the defendant a designer, manufacturer, distributor, or reseller?¹

4. Set forth the names, addresses, and relationships to the parties of each designer, manufacturer, distributor and reseller of the Product.²

5. Set forth the names, addresses, and relationships to the parties of each person who has knowledge of relevant facts involving the design, manufacture, distribution or sale of the Product with respect to this litigation.

6. If the Defendant ___________, Inc. designed the Product, state:

   1. The date or dates upon which the design of the Product commenced and the date or dates upon which the design or was completed.

   2. The specific location and address of the design operation.

   3. The name, address, telephone number and job title of each individual involved in the design of the Product, and a brief description of his or her involvement.

   4. A description of each stage of the design process, setting forth dates and the names of the individuals involved.

   5. Who, if anyone applied for or obtained a patent with respect to the design process? For each patent related to the Product, please state: [i] The present stage of the application process, [ii] the application number, [iii] whether the application seeks a design patent or a utility patent.

7. Do any employees or agents of the Defendant ___________, Inc. have custody or access to, or know the whereabouts of any documents, writings or memos pertaining to the design process? If so, for each document, memo or writing, please set forth the following information:

   1. Its title, author, date, the person or persons for whom it was intended and a brief summary of its contents.

   2. The name, address, telephone number and relationship to the parties of each custodian of a copy.

   3. The present location of the writing.

8. If the Defendant ___________, Inc. has ever manufactured the product, please state:

   1. The date upon which the Defendant __________ first began to manufacture the product.

   2. The date upon which the Defendant __________ ceased manufacturing. Set forth in detail, the reason for such cessation.

   3. The name, address, telephone number and job title of each individual involved in the manufacture of the Product, and a brief description of his or her...