Plaintiff's Contention Interrogatories to Defendant

1. If you contend that the defendant is improperly identified, give its proper identification, and state whether you will accept service of an amended summons and complaint reflecting this information.

2. Describe in detail the factual bases for the defenses you assert in your answer.

3. If you contend that some other person or entity is or may be liable, in whole or in part, to the plaintiff or to the defendant, identify that person or entity as well as the alleged bases of liability.

4. Identify all laws, codes, standards, customs or usages you contend are applicable to any claim or defense in this action.

5. 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...