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Leonard T. Fink, Esq., SBN 171735Kathryn L. Kim, Esq., SBN 238658Benjamin J. Angulo, Esq., SBN 2901 12SPRINGEL & FINK LLP18100 Von Karman Ave., Suite 750Irvine, CA 92612
Telephone: (714) 957-5742 / (714) 957-5762
Attorneys for Defendant/Cross-Defendant, COURTNEY, INC. erroneously sued and served asCOURTNEY WATERPROOFING, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA CLARA
CILKER APARTMENTS, LLC,; ) Case No.: 1 13CV258281) [Assigned to: Hon. Peter H Kinvan
Plaintiff, ^ Dept. 1
vs. )) RESPONSES TO PLAINTIFF CILKERWESTERN NATIONAL CONSTRUCTION, et ) APARTMENTS, LLC'S SPECIAL
ah, ) INTERROGATORIES, SET ONE
Defendants. ^ ) Complaint Filed: December 26, 201 3
) Trial Date: June 13, 2016AND RELATED CROSS-ACTIONS )
))
PROPOUNDING PARTY: CILKER APARTMENTS, LLC
RESPONDING PARTY: COURTNEY, INC
SET NO.: ONE
Defendant/Cross-Defendant, COURTNEY, INC. (hereinafter "Courtney") hereby provides
responses to Plaintiff, CILKER APARTMENTS, LLC'S Special Interrogatories - Set One as follows.
PRELIMINARY STATEMENT
These responses are made solely for the purpose of this action. Each response is subject to all
appropriate objections which would require the exclusion of any statement contained herein if the
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RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLCS SPECIAL INTERROGATORIES, SET ONE
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Interrogatories were asked of a witness present and testifying in court. All objections and grounds are
reserved and may be interposed at the time of trial.
This responding party has not yet completed its investigation of the facts relating to this action,
its discovery in this action, or its preparation for trial of this action. Consequently, these responses are
given without prejudice to the right of any responding party to produce at the time of trial, and all
subsequently discovered evidence relating to the proof of the presently known material facts, and to
produce all evidence, whether discovered, relating to the proof of subsequently discovered material
facts.
Except for the explicit facts admitted herein, no admissions of any nature whatsoever are implied
or should be inferred. The fact that any Interrogatory herein has been responded to should not be taken
as an admission or acceptance of the existence of any fact or facts as set forth or assumed by such
Interrogatory, or that such answer constitutes admissible evidence.
It is assumed by this responding party that the party propounding the Interrogatories and all
parties to this lawsuit possess and are familiar with the entire product of discovery proceedings in this
action. Therefore, when an Interrogatory calls for information which is contained in the discovery
materials available to all parties, said Interrogatory will be responded to only by reference to those
discovery materials.
This preliminary statement is, by this reference, incorporated into each and every answer to these
Interrogatories.
RESPONSES TO SPECIAL INTERROGATORIES
SPECIAL INTERROGATORY NO. X:
Please IDENTIFY the name, address, phone number, and job title of each person who
participated in the preparation of YOUR responses to these Interrogatories.
ANSWER TO SPECIAL INTERROGATORY NO. I:
Leonard T. Fink and Benjamin J. Angulo of Springel & Fink LLP, counsel for Courtney. 575
Market Street, Suite 2200, San Francisco, California 94105. (415) 541-5363.
SPECIAL INTERROGATORY NO. 2:
Please describe the work or services YOU performed on the PROJECT.
RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLCS SPECIAL INTERROGATORIES, SET ONE
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ANSWER TO SPECIAL INTERROGATORY NO, 2:
Objection, SPECIAL INTERROGATORY NO. 2 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989).
SPECIAL INTERROGATORY NO. 3:
Please describe the materials YOU provided or supplied for work on the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 3:
Objection. SPECIAL INTERROGATORY NO. 3 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490(1989).
SPECIAL INTERROGATORY NO. 4:
Please IDENTIFY the name, address, phone number and job title of all persons who performed
YOUR work on the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 4:
Objection. SPECIAL INTERROGATORY NO. 4 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
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3d 490 (1989).
SPECIAL INTERROGATORY NO. 5:
Please IDENTIFY all contracts YOU entered into with respect to the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 5:
Objection. SPECIAL INTERROGATORY NO. 5 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt. , 207 Cal. App.
3d 490 (1989).
SPECIAL INTERROGATORY NO. 6:
Please IDENTIFY each person negotiated the terms and conditions of the contracts identified in
YOUR response to Special Interrogatory No. 5.
ANSWER TO SPECIAL INTERROGATORY NO. 6:
Objection. SPECIAL INTERROGATORY NO. 6 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989).
SPECIAL INTERROGATORY NO. 7:
Please IDENTIFY all written change orders with respect to YOUR scope of work on the
PROJECT.
///
RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLC.'S SPECIAL INTERROGATORIES, SET ONE
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ANSWER TO SPECIAL INTERROGATORY NO. 7:
Objection, SPECIAL INTERROGATORY NO. 7 seeks information that was already answered
per Case Management Order No. I. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Cri., 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 8:
Please IDENTIFY each person negotiated the terms and conditions of the change orders
identified in YOUR response to Special Interrogatory No. 7.
ANSWER TO SPECIAL INTERROGATORY NO. 8:
Objection. SPECIAL INTERROGATORY NO. 8 seeks information that was already answered
per Case Management Order No.I. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC072616) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 9:
Do YOU contend that YOU performed YOUR work on the PROJECT in compliance with
YOUR contract?
///
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ANSWER TO SPECIAL INTERROGATORY NO. 9;
Objection. SPECIAL INTERROGATORY NO. 9 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). Further, this interrogatory impermissibly calls for a legal conclusion. Without waiving
the above objections and subject to them, Courtney responds as follows: See Western National
Construction's letter dated on February 13, 2003 (See WNC072616) and Change Order No. 4 dated on
February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 10:
Please state all facts which support YOUR response to Special Interrogatory No. 9.
ANSWER TO SPECIAL INTERROGATORY NO. 10:
Objection. SPECIAL INTERROGATORY NO. 10 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt. , 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC072616) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 11:
Do YOU contend that YOU performed YOUR work on the PROJECT in compliance with the
plans and specifications?
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ANSWER TO SPECIAL INTERROGATORY NO. 11:
Objection. SPECIAL INTERROGATORY NO. 1 1 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt, 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. Without waiving the
above objections and subject to them, Courtney responds as follows: See Western National
Construction's letter dated on February 13, 2003 (See WNC072616) and Change Order No. 4 dated on
February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 12:
Please state all facts which support YOUR response to Special Interrogatory No. 1 1 .
ANSWER TO SPECIAL INTERROGATORY NO. 12:
Objection. SPECIAL INTERROGATORY NO. 12 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC07261 6) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 13:
Do YOU contend that YOU performed YOUR work on the PROJECT in compliance with all
relevant industry standards?
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ANSWER TO SPECIAL INTERROGATORY NO. 13:
Objection. SPECIAL INTERROGATORY NO. 13 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Ol, 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. It also impermissibly
calls for an expert opinion. Without waiving the above objections and subject to them, Courtney
responds as follows: See Western National Construction's letter dated on February 13, 2003 (See
WNC072616) and Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 14:
Please state all facts which support YOUR response to Special Interrogatory No. 13.
ANSWER TO SPECIAL INTERROGATORY NO. 14:
Objection. SPECIAL INTERROGATORY NO. 14 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt, 207 CaL App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC072616) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 15:
Do YOU contend that YOU performed YOUR work on the PROJECT in compliance with all
relevant manufacturer recommendations?
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ANSWER TO SPECIAL INTERROGATORY NO. 15:
Objection. SPECIAL INTERROGATORY NO. 15 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. It also impermissibly
calls for an expert opinion. Without waiving the above objections and subject to them, Courtney
responds as follows: See Western National Construction's letter dated on February 13, 2003 (See
WNC072616) and Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 16:
Please state all facts which support YOUR response to Special Interrogatory No. 15.
ANSWER TO SPECIAL INTERROGATORY NO. 16:
Objection. SPECIAL INTERROGATORY NO. 16 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC072616) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 17:
Do YOU contend that YOU performed YOUR work on the PROJECT in compliance with all
relevant ordinances, codes or statutes?
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ANSWER TO SPECIAL INTERROGATORY NO. 17:
Objection. SPECIAL INTERROGATORY NO. 17 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Of., 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. It also impermissibly
calls for an expert opinion. Without waiving the above objections and subject to them, Courtney
responds as follows: See Western National Construction's letter dated on February 13, 2003 (See
WNC072616) and Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 18:
Please state all facts which support YOUR response to Special Interrogatory No. 17.
ANSWER TO SPECIAL INTERROGATORY NO. 18:
Objection. SPECIAL INTERROGATORY NO. 1 8 seeks information that was already answered
per Case Management Order No.l. Thus, Plaintiff already has access to this information per the Case
Management Order and can access ail contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). Without waiving the above objections and subject to them, Courtney responds as
follows: See Western National Construction's letter dated on February 13, 2003 (See WNC072616) and
Change Order No. 4 dated on February 24, 2003 (See CWI0033).
SPECIAL INTERROGATORY NO. 19:
Does YOUR contract for work on the PROJECT require YOU to indemnify any party for
damages and/or losses relating to the PROJECT?
- 10RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLC'S SPECIAL INTERROGATORIES, SET ONE
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ANSWER TO SPECIAL INTERROGATORY NO. 19:
Objection. SPECIAL INTERROGATORY NO. 1 9 impermissibly calls for a legal conclusion. It
also seeks information that was already provided per Case Management Order No.l . Thus, Plaintiff has
access to this information per the Case Management Order and can access all contracts at Aiken Welch's
online depository. Assuming arguendo Plaintiff believes Courtney's previously provided information
concerning its scope of work at One Pearl Place located at 5210 Temer Way, San Jose, CA was
inadequate. Plaintiff cannot use this interrogatory as another attempt to seek information that was
already sought under the Case Management Order No. 1 interrogatories per Professional Career
Colleges v. Sup. Crt.t 207 Cal. App. 3d 490 (1989).
SPECIAL INTERROGATORY NO. 20:
If YOUR response to Special Interrogatory No. 1 9 is "yes" please state who are YOU required to
indemnify for damages and/or losses relating to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 20:
Objection. SPECIAL INTERROGATORY NO. 20 impermissibly calls for a legal conclusion. It
also seeks information that was already provided per Case Management Order No.l. Thus, Plaintiff has
access to this information per the Case Management Order and can access all contracts at Aiken Welch's
online depository. Assuming arguendo Plaintiff believes Courtney's previously provided information
concerning its scope of work at One Pearl Place located at 5210 Temer Way, San Jose, CA was
inadequate, Plaintiff cannot use this interrogatory as another attempt to seek information that was
already sought under the Case Management Order No. 1 interrogatories per Professional Career
Colleges v. Sup. Crt., 207 Cal. App. 3d 490 (1989).
SPECIAL INTERROGATORY NO. 21:
Does YOUR contract for work on the PROJECT require YOU to defend any party for damages
and/or losses relating to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 21:
Objection. SPECIAL INTERROGATORY NO. 21 is vague and ambiguous in its entirety.
Further, it assumes facts not in evidence by stating Courtney was required to defend any party for
damages and/or losses relating to the PROJECT. Tins interrogatory seeks information that was already
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answered per Case Management Order No. 1 . Plaintiff already has access to this information per the
Case Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. Without waiving the
above objections and subject to diem, Courtney responds as follows: Assuming arguendo Plaintiff
believes Courtney is required to defend Plaintiff from damages and/or losses, Plaintiff has not produced
evidence showing that it needs defense from a third party against damages and/or losses relating to the
PROJECT as it relates to Courtney's scope of work if Courtney indeed had the obligation to do so.
SPECIAL INTERROGATORY NO. 22:
IfYOUR response to Special Interrogatory No, 21 is "yes" please state who are YOU required to
defend for damages and/or losses relating to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 22:
Objection. SPECIAL INTERROGATORY NO. 22 is vague and ambiguous in its entirety.
Further it assumes facts not in evidence by stating Courtney was required to defend any party for
damages and/or losses relating to the PROJECT. This interrogatory seeks information that was already
answered per Case Management Order No.l. Plaintiff already has access to this information per the
Case Management Order and can access all contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way, San Jose, CA was inadequate, Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Crt., 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. Without waiving the
above objections and subject to them, Courtney responds as follows: Assuming arguendo Plaintiff
believes Courtney is required to defend Plaintiff from damages and/or losses, Plaintiff has not produced
evidence showing that it needs defense from a third party against damages and/or losses relating to the
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PROJECT as it relates to Courtney's scope of work if Courtney indeed had the obligation to do so.
SPECIAL INTERROGATORY NO. 23:
Do YOU contend that YOU are not required to indemnify propounding party for damages and/or
losses relating to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 23:
Objection. SPECIAL INTERROGATORY NO. 23 seeks information that impermissibly calls
for a legal conclusion. It is also vague and ambiguous in its entirety. This interrogatory seeks
information that was already answered per Case Management Order No.l. Plaintiff already has access
to this information per the Case Management Order and can access all contracts at Aiken Welch's online
depository- Assuming arguendo Plaintiff believes Courtney's previously provided information
concerning its scope of work at One Pearl Place located at 5210 Terner Way, San Jose, CA was
inadequate, Plaintiff cannot use this interrogatory as another attempt to seek information that was
already sought under the Case Management Order No. 1 interrogatories per Professional Career
Colleges v. Sup. Crt., 207 Cal. App. 3d 490 (1989).
SPECIAL INTERROGATORY NO. 24:
Please state all facts which support YOUR response to Special Interrogatory No. 23.
ANSWER TO SPECIAL INTERROGATORY NO. 24:
Objection. SPECIAL INTERROGATORY NO. 24 is vague and ambiguous in its entirety. This
interrogatory seeks information that was already answered per Case Management Order No.l. Plaintiff
already has access to this information per the Case Management Order and can access all contracts at
Aiken Welch's online depository. Assuming arguendo Plaintiff believes Courtney's previously
provided information concerning its scope of work at One Pearl Place located at 5210 Temer Way, San
Jose, CA was inadequate. Plaintiff cannot use this interrogatory as another attempt to seek infonnation
that was already sought under the Case Management Order No. 1 interrogatories per Professional
Career Colleges v. Sup. Crt., 207 Cal. App. 3d 490 (1989).
SPECIAL INTERROGATORY NO. 25:
Do YOU contend that YOU are not required to defend propounding party for damages and/or
losses relating to the PROJECT?
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ANSWER TO SPECIAL INTERROGATORY NO. 25:
Objection. SPECIAL INTERROGATORY NO. 25 is vague and ambiguous in its entirety.
Further it assumes facts not in evidence by inferring Courtney was required to defend any party for
damages and/or losses relating to the PROJECT. This interrogatory seeks information that was already
answered per Case Management Order No.l. Plaintiff already has access to this information per the
Case Management Order and can access ail contracts at Aiken Welch's online depository. Assuming
arguendo Plaintiff believes Courtney's previously provided information concerning its scope of work at
One Pearl Place located at 5210 Terner Way. San Jose, CA was inadequate. Plaintiff cannot use this
interrogatory as another attempt to seek information that was already sought under the Case
Management Order No. 1 interrogatories per Professional Career Colleges v. Sup. Of., 207 Cal. App.
3d 490 (1989). This interrogatory also impermissibly calls for a legal conclusion. Without waiving the
above objections and subject to them, Courtney responds as follows: Assuming arguendo Plaintiff
believes Courtney is required to defend Plaintiff from damages and/or losses, Plaintiff has not produced
evidence showing that it needs defense from a third party against damages and/or losses relating to the
PROJECT as it relates to Courtney's scope of work if Courtney indeed had the obligation to do so.
SPECIAL INTERROGATORY NO. 26:
Please state all facts which support YOUR response to Special Interrogatory No. 25.
ANSWER TO SPECIAL INTERROGATORY NO. 26:
Objection. SPECIAL INTERROGATORY NO. 26 is vague and ambiguous in its entirety. This
interrogatory seeks information that was already answered per Case Management Order No.l. Plaintiff
already has access to this information per the Case Management Order and can access all contracts at
Aiken Welch's online depository. Assuming arguendo Plaintiff believes Courtney's previously
provided information concerning its scope of work at One Pearl Place located at 5210 Terner Way, San
Jose, CA was inadequate, Plaintiff cannot use this interrogatory as another attempt to seek information
that was already sought under the Case Management Order No. 1 interrogatories per Professional
Career Colleges v. Sup. Crt., 207 Cal. App. 3d 490 (1989). Without waiving the above objections and
subject to them, Courtney responds as follows: Assuming arguendo Plaintiff believes Courtney is
required to defend Plaintiff from damages and/or losses, Plaintiff has not produced evidence showing
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that it needs defense from a third party against damages and/or losses relating to the PROJECT as it
relates to Courtney's scope of work if Courtney indeed had the obligation to do so.
SPECIAL INTERROGATORY NO. 27:
Who do YOU contend, if anyone, is required to indemnify YOU for damages and/or losses
relating to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 27:
Objection. SPECIAL INTERROGATORY NO. 27 seeks information that impermissibly calls
for a legal conclusion. It is also vague and ambiguous in its entirety. Without waiving the above
objections and subject to them, Courtney responds as follows: Informed and believes no.
SPECIAL INTERROGATORY NO. 28:
Please state all facts which support YOUR response to Special Interrogatory No. 27.
ANSWER TO SPECIAL INTERROGATORY NO. 28:
N/A
SPECIAL INTERROGATORY NO. 29:
Who do YOU contend, if anyone, is required to defend YOU for damages and/or losses relating
to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 29:
Objection. SPECIAL INTERROGATORY NO. 29 seeks information that impermissibly calls
for a legal conclusion. It is also vague and ambiguous in its entirety. Without waiving the above
objections and subject to them, Courtney responds as follows: Informed and believes not applicable.
SPECIAL INTERROGATORY NO. 30:
Please state all facts which support YOUR response to Special Interrogatory No. 29.
ANSWER TO SPECIAL INTERROGATORY NO. 30:
N/A
SPECIAL INTERROGATORY NO. 31:
Who, if anyone, are YOU required to name as an additional named insured on YOUR liability
insurance policy?
///
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ANSWER TO SPECIAL INTERROGATORY NO. 31:
Upon information and belief: Plaintiff and Western National Construction. Courtney reserves its
right to amend and/or supplement this response as additional information is discovered.
SPECIAL INTERROGATORY NO. 32:
Who do YOU contend, if anyone, is required to name YOU as an additional named insured on its
liability insurance policy?
ANSWER TO SPECIAL INTERROGATORY NO. 32:
Objection. This interrogatory seeks information that was already answered per Case
Management Order No. 1 . Plaintiff already has access to this information per the Case Management
Order and can access all contracts at Aiken Welch's online depository. Assuming arguendo Plaintiff
believes Courtney's previously provided information concerning its scope of work at One Pearl Place
located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this interrogatory as
another attempt to seek information that was already sought under the Case Management Order No. 1
interrogatories per Professional Career Colleges v. Sup, Crt, , 207 Cal. App. 3d 490 (1 989).
SPECIAL INTERROGATORY NO. 33:
Please state all facts which support YOUR response to Special Interrogatory No. 32.
ANSWER TO SPECIAL INTERROGATORY NO. 33:
Objection. This interrogatory seeks information that was already answered per Case
Management Order No. 1 . Plaintiff already has access to this infonnation per the Case Management
Order and can access all contracts at Aiken Welch's online depository. Assuming arguendo Plaintiff
believes Courtney's previously provided information concerning its scope of work at One Pearl Place
located at 5210 Temer Way, San Jose, CA was inadequate, Plaintiff cannot use this interrogatory as
another attempt to seek infonnation that was already sought under the Case Management Order No. 1
interrogatories per Professional Career Colleges v. Sup. Crt,, 207 Cal. App. 3d 490 (1989).
SPECIAL INTERROGATORY NO. 34:
Do YOU contend that YOU did not cause or contribute to any of the damages claimed by
propounding party in this case?
Hi
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ANSWER TO SPECIAL INTERROGATORY NO. 34:
Objection. This intenogatory is an impermissible compound or conjunctive. Without waiving the
above objection and subject to it, Courtney responds as follows: Informed and believes Plaintiff has not
produced evidence indicating Courtney caused or contributed to any damages claimed by propounding
party in this case.
SPECIAL INTERROGATORY NO. 35:
Please state all facts which support YOUR response to Special Interrogatory No. 34.
ANSWER TO SPECIAL INTERROGATORY NO. 35:
Informed and believes Plaintiff has not produced evidence indicating Courtney caused or
contributed to any damages claimed by propounding party in this case.
SPECIAL INTERROGATORY NO. 36:
Do YOU contend that any of propounding party's alleged damages are unreasonable?
ANSWER TO SPECIAL INTERROGATORY NO. 36:
Objection. SPECIAL INTERROGATORY NO. 36 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 37:
Please state all facts which support YOUR response to Special Interrogatory No. 36.
ANSWER TO SPECIAL INTERROGATORY NO. 37:
Objection. SPECIAL INTERROGATORY NO. 37 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 38:
Do YOU contend that any of propounding party's alleged damages are not related to YOUR
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scope of work?
ANSWER TO SPECIAL INTERROGATORY NO. 38:
Objection. SPECIAL INTERROGATORY NO. 38 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 39:
Please state all facts which support YOUR response to Special interrogatory No. 38.
ANSWER TO SPECIAL INTERROGATORY NO. 39:
Objection. SPECIAL INTERROGATORY NO. 39 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 40:
Do YOU contend that any of propounding party's proposed repairs are unreasonable?
ANSWER TO SPECIAL INTERROGATORY NO. 40:
Objection. SPECIAL INTERROGATORY NO. 40 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 41:
Please state all facts which support YOUR response to Special Interrogatory No. 40.
ANSWER TO SPECIAL INTERROGATORY NO. 41:
Objection. SPECIAL INTERROGATORY NO. 41 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
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declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 42:
Do YOU contend that any of propounding party's proposed cost of repairs are unreasonable?
ANSWER TO SPECIAL INTERROGATORY NO. 42:
Objection. SPECIAL INTERROGATORY NO. 42 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutoiy limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 43:
Please state all facts which support YOUR response to Special Interrogatory No. 42.
ANSWER TO SPECIAL INTERROGATORY NO. 43:
Objection. SPECIAL INTERROGATORY NO. 43 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are wan-anted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 44:
Please IDENTIFY who was responsible for supervising YOUR work on the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 44:
Objection. SPECIAL INTERROGATORY NO. 44 violates California Code of Civil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
m
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SPECIAL INTERROGATORY NO. 45:
Please state all facts which support YOUR response to Special Interrogatory No. 44.
ANSWER TO SPECIAL INTERROGATORY NO. 45:
Objection. SPECIAL INTERROGATORY NO. 45 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 46:
Do YOU contend that YOU were not required to supervise YOUR work on the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 46:
Objection. SPECIAL INTERROGATORY NO. 46 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 47:
Please state all facts which support YOUR response to Special Interrogatory No. 46.
ANSWER TO SPECIAL INTERROGATORY NO. 47:
Objection. SPECIAL INTERROGATORY NO. 47 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 48:
Do YOU contend that propounding party was responsible for supervising YOUR work on the
PROJECT?
HI
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ANSWER TO SPECIAL INTERROGATORY NO. 48:
Objection. SPECIAL INTERROGATORY NO. 48 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 49:
Please state all facts which support YOUR response to Special Interrogatory No. 48.
ANSWER TO SPECIAL INTERROGATORY NO. 49:
Objection. SPECIAL INTERROGATORY NO. 49 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 50:
Do YOU contend that propounding party inadequately supervised YOUR work on the
PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 50:
Objection. SPECIAL INTERROGATORY NO. 50 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 51:
Please state all facts which support YOUR response to Special Interrogatory No. 50.
ANSWER TO SPECIAL INTERROGATORY NO. 51:
Objection. SPECIAL INTERROGATORY NO. 51 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
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declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 52:
Who was responsible for inspecting YOUR work on the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 52:
Objection. SPECIAL INTERROGATORY NO. 52 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 53:
Please state all facts which support YOUR response to Special Interrogatory No. 52.
ANSWER TO SPECIAL INTERROGATORY NO. 53:
Objection. SPECIAL INTERROGATORY NO. 53 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 54:
Do YOU contend that YOU were not required to inspect YOUR work on the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 54:
Objection. SPECIAL INTERROGATORY NO. 54 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutoiy limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
Ill
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SPECIAL INTERROGATORY NO. 55:
Please state all facts which support YOUR response to Special Interrogatory No. 54.
ANSWER TO SPECIAL INTERROGATORY NO. 55:
Objection. SPECIAL INTERROGATORY NO. 55 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has show that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.03Q(c).
SPECIAL INTERROGATORY NO. 56:
Do YOU contend that propounding party was responsible for inspecting YOUR work on the
PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 56:
Objection. SPECIAL INTERROGATORY NO. 56 violates California Code ofCivil Procedure,
§2030.030(0) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 57:
Please state all facts which support YOUR response to Special Interrogatory No. 56.
ANSWER TO SPECIAL INTERROGATORY NO. 57:
Objection. SPECIAL INTERROGATORY NO. 57 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus. Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 58:
Do YOU contend that propounding party inadequately inspected YOUR work on the PROJECT?
HI
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ANSWER TO SPECIAL INTERROGATORY NO. 58:
Objection. SPECIAL INTERROGATORY NO. 58 violates California Code ofCivil Procedure,
§2030.03Q(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 59:
Please state all facts which support YOUR response to Special Interrogatory No. 58.
ANSWER TO SPECIAL INTERROGATORY NO. 59:
Objection. SPECIAL INTERROGATORY NO. 59 violates California Code ofCivil Procedure,
§2030.030(h) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 60:
What role, if any, did YOU play in creation of the plans and specifications for the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 60:
Objection. SPECIAL INTERROGATORY NO. 60 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §203Q.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO, 61:
Do YOU contend that the plans and specifications for the PROJECT are ambiguous?
ANSWER TO SPECIAL INTERROGATORY NO. 61:
Objection. SPECIAL INTERROGATORY NO. 61 violates California Code ofCivil Procedure,
§2030.030(h) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
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prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a), Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 62;
Please state all facts which support YOUR response to Special Interrogatory No. 61.
ANSWER TO SPECIAL INTERROGATORY NO. 62:
Objection. SPECIAL INTERROGATORY NO. 62 violates California Code of Civil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2020.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 63:
Do YOU contend that the plans and specifications for the PROJECT do not provide adequate
detail for proper construction?
ANSWER TO SPECIAL INTERROGATORY NO. 63:
Objection. SPECIAL INTERROGATORY NO. 63 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c) .
SPECIAL INTERROGATORY NO, 64:
Please state all facts which support YOUR response to Special Interrogatory No. 63.
ANSWER TO SPECIAL INTERROGATORY NO. 64:
Objection. SPECIAL INTERROGATORY NO. 64 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
II!
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SPECIAL INTERROGATORY NO. 65:
Do YOU contend that the plans and specifications for the PROJECT are deficient in any
manner?
ANSWER TO SPECIAL INTERROGATORY NO. 65:
Objection. SPECIAL INTERROGATORY NO. 65 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus. Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 66:
Please state all facts which support YOUR response to Special Interrogatory No. 65.
ANSWER TO SPECIAL INTERROGATORY NO. 66:
Objection. SPECIAL INTERROGATORY NO. 66 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 67:
Do YOU have any criticisms of the plans and specifications for the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 67:
Objection. SPECIAL INTERROGATORY NO. 67 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 68:
Please state all criticisms YOU identified in response to Special Interrogatory No. 67.
Hi
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ANSWER TO SPECIAL INTERROGATORY NO. 68:
Objection. SPECIAL INTERROGATORY NO. 68 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 69:
Please describe each and every repair YOU made to the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 69*.
Objection. SPECIAL INTERROGATORY NO. 69 violates California Code ofCivil Procedure,
§2030.030(0) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 70:
Please describe any and all repairs YOU propose with respect to the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 70:
Objection. SPECIAL INTERROGATORY NO. 70 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 71:
Please describe any and all repair estimates YOU prepared with respect to the PROJECT.
ANSWER TO SPECIAL INTERROGATORY NO. 71:
Objection. SPECIAL INTERROGATORY NO. 71 violates California Code ofCivil Procedure,
§2030,030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further. Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
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prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 72:
Do YOU contend that propounding party has entered into any settlement agreement or release of
any claims with YOU with respect to the PROJECT?
ANSWER TO SPECIAL INTERROGATORY NO. 72:
Objection. SPECIAL INTERROGATORY NO. 72 violates California Code ofCivil Procedure,
§2030.030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further. Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this inten'ogatory per Code Civ. Proc., §2030.030(c).
SPECIAL INTERROGATORY NO. 73:
Please state all facts which support YOUR response to Special Interrogatory No. 72.
ANSWER TO SPECIAL INTERROGATORY NO. 73:
Objection. SPECIAL INTERROGATORY NO. 73 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030.2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 74:
Have you, YOUR attorneys, or any person to YOUR knowledge obtained any oral or written
statements, of any kind or nature, concerning the PROJECT or any of the issues or damages alleged in
the complaint from any persons claiming to have knowledge of the facts relevant to the damage alleged
in the complaint?
ANSWER TO SPECIAL INTERROGATORY NO. 74:
Objection. SPECIAL INTERROGATORY NO. 74 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
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prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
SPECIAL INTERROGATORY NO. 75:
If YOUR answer to Special Interrogatory No. 74 is in the affirmative, please IDENTIFY all such
persons and the type of statement obtained.
ANSWER TO SPECIAL INTERROGATORY NO. 75:
Objection. SPECIAL INTERROGATORY NO. 75 violates California Code ofCivil Procedure,
§2030. 030(b) by exceeding the 35 specially prepared interrogatory statutory limit. Further, Plaintiffs
declaration does not satisfy Code Civ. Proc., §2030.2050 or has shown that more than 35 specially
prepared interrogatories are warranted per Code Civ. Proc., §2030. 2040(a). Thus, Courtney is not
providing a response to this interrogatory per Code Civ. Proc., §2030. 030(c).
DATED: November 23, 2015 SPRINGEL & FINK LLP
Kathryn L. Kim
Benjamin J. Angulo
Attorneys for Defendant/Cross-Defendant,COURTNEY, INC. erroneously sued and served asCOURTNEY WATERPROOFING, INC.
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RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLC.'S SPECIAL INTERROGATORIES, SET ONE
VERIFICATIONSTATE OF CALIFORNIA, COUNTY OF SANTA CLARA
I have read the foregoing RESPONSES TO PLAINTIFF CILKER APARTMENTS. LLC'S SPECIALINTERROGATORIES, SET ONE and know its contents.
m CHECK APPLICABLE PARAGRAPHSI] I am a party to this action. The matters stated in the foregoing document are true of my own knowledge except as tothose matters which are stated on information and belief, and as to those matters I believe them to be true.
[D I am I I an Officer I I a partner I x I a n agent of COURTNEY. INC.
a party to this action, and am authorized to make this verification for and on its behalf, and I make this verification for thatreason. HTI I am informed and believe and on that ground allege that the matters stated in the foregoing document aretrue. I x I The matters stated In the foregoing document are true of my own knowledge, except as to those matters which arestated on information and belief, and as to those matters I believe them to be true.
J 1 am one of the attorneys for a party to this action. Such party is absent from the county of aforesaid where such attorneys have their offices, and I makethis verification for and on behalf of that party for that reason. I am informed and believe and on that ground allege thatthe matters stated In the foregoing document are true.Executed on November 23. 2015 . at Irvine , California.I declare under penalty of peijury under the laws of the Stale of California that the foregoing is true and correc
GARY TOLLERTypa or Print Name
—• ¦
SignaturePROOF OF SERVICE
1012h (3) CCP Revised 5/1 /8B
STATE OF CALIFORNIA, COUNTY OF
I am employed in the county of , State of California.1 am over the age of 18 and not a party to the within action; my business address is;
On, I served the foregoing document described as
on in this action.. W| I
I i by placing the tme copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list:i I by placing I I the original II a true copy thereof enclosed in sealed envelopes addressed as follows:
J BY MAIL
i I 'I deposited such envelope in the mail at , California.The envelope was mailed with postage thereon fully prepaid.
I I As follows: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing.Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at California in the ordinary course of business. I am aware that on motion of theparty served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date ofdeposit for mailing in affidavit.Executed on , at , California.
] "(BY PERSONAL SERVICE) I delivered such envelope by hand to the offices of the addressee-Executed on , at , California.
] (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct.] (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.
Typa or Print Name Signature
•(BY MAIL SIGNATURE MUST BE OF PERSON DEPOSITING ENVELOPE INMAIL SLOT. BOX, OR BAG)
-(FOR PERSONAL SERVICE SIGNATURE MUST BE THAT OF MESSENGER)
dSol$&aPius
Rev. 7m
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PROOF OF SERVICE
I am employed in the City of Irvine, County of Orange, State of California. I am over the age of18 years and not a party to the within action. My business address is 18100 Von Karman Avenue, Suite750, Irvine, CA 92612. On November 23, 2015, 1 served the documents named below on the parties inthis action as follows:
DOCUMENT(S) SERVED: RESPONSES TO PLAINTIFF CILKER APARTMENTS, LLC'SSPECIAL INTERROGATORIES, SET ONE
SERVED UPON: SEE ATTACHED SERVICE LIST
[ ] (BY MAIL) I am readily familiar with Springel & Fink LLP's practice for collection andprocessing of documents for mailing with the United States Postal Service. I caused suchdocument(s) to be placed in a sealed envelope, addressed to the person(s) on whom it is to bedelivered pursuant to the attached service list, with postage thereon fully prepaid, to be depositedwith the United States mail at Irvine, California that same day in the ordinary course of business.[CCP §1013]
[X ] (BY ELECTRONIC SERVICE) I caused such document(s) to be electronically served, via theCourt's Website http://www.scefiling.org, served on all interested parties in this action shown byElectronic-Filing through http://www.scefiling.org which is then printed and maintained with theoriginal documents in our office.
[ ] (BY CERTIFIED MAIL/RETURN RECEIPT REQUESTED) I am readily familiar withSpringel & Fink LLP's practice for collection and processing of documents for mailing viacertified mail with the United States Postal Service. I caused such document(s) to be placed in asealed envelope, addressed to the person(s) on whom it is to be delivered pursuant to the attachedservice list, with postage thereon fully prepaid, marked certified and return receipt requested, tobe deposited with the United States mail at Irvine, California that same day in the ordinarycourse of business. [CCP §11]
[ ] (BY OVERNIGHT MAIL) I am readily familiar with Springel & Fink, LLP's practice forcollection and processing of documents for mailing via overnight delivery. I caused suchdocument(s) to be placed in a sealed envelope designated by the overnight service carrier,addressed to the person(s) on whom it is to be served pursuant to the attached service list, anddeposited said envelope in a box or other facility regularly maintained by the overnight servicecarrier with delivery fees paid or provided for. [CCP § 1 0 1 3(c)]
[ ] (BY FACSIMILE) I caused the document(s) described herein to be transmitted by facsimile tothe facsimile number(s) for each party indicated on the attached service list. [CCP § 1013(e)]
[X] (STATE) I declare under penalty of perjury under the laws of the State of California that theforegoing is true and correct.
Executed on November 23, 2015, at Irvine, California.
Ann Porter
{C0161016; 1}
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Cilker Apartments, LLC v. Weslern National Construction Corp.
SERVICE LIST
Jon B. Zimmerman, Esq.
Steven M. Wheeler, Esq.ROBINSON & WOOD, INC.227 N. 1st StreetSan Jose, CA95n3
(408) 298-7120; Fax: (408) 298-0477
[email protected]@robinsonwood.com;
Attorneys for Plaintiff
Michael A. Erlinger, Esq.Sophia S. DeFrancis, Esq.GREEN & HALL, APC1851 E. First Street, 10th FloorSanta Ana, CA 92705
(7 1 4) 9 1 8-7000; Fax: (7 14)91 8-6996se 1 1 is@ greenhall .com
Attorneys for Western National
Construction Corp.
Jenna L. Fischer-Reyes, Esq.
LAW OFFICES OF MELISSA M.BALLARD
1551 North Tustin Avenue, Suite 830Santa Ana, CA 92705(714) 547-0407; Fax: (877) 369-5799
Direct: (714) [email protected] Address:
P.O. Box 2282, Brea, CA 92822Attorneys for Robecks Welding &Fabrication, Inc.
Thomas B. Wait, Esq.Robert A. Hufnagel, Esq.Matthew P. Malczynski, Esq.
WAIT & HUFNAGEL250 West First Street, Suite 222
Claremont, CA 9171 [email protected]@[email protected]@wait-hufhagel.com(909) 621-5672; Fax: (909) 399-0645
Attorneys for Tara Coatings, Inc.
Richard N. Sieving, Esq.Luke G. Pears-Dickson, Esq.THE SIEVING LAW FIRM100 Howe Avenue, Suite 220N
Sacramento, CA 95825(9 1 6) 444-3366; Fax: (9 1 6) 444- 1 223
[email protected]@sievinglawfirm.comAttorneys for Jeld-Wen, Inc. dba SummitWindow & Patio Door
Todd A. Jones, Esq.Gregory K. Federico, Esq.
ARCHER NORRIS301 University Avenue, Suite 1 10 Sacramento,CA 95825 [email protected]
[email protected] (916) 646-2480;Fax: (916) 646-5696
Attorneys for Robecks Welding &Fabrication, Inc.
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Laura K. Buttrell, Esq.
LAW OFFICES OF DAVID A. WALLIS2251 Harvard Street, Suite 100Sacramento, CA 95814
(916) 921-9353; Fax: (916) [email protected] for Robecks Welding &Fabrication; Eastern LandscapeCompany
Michael L. Marx, Esq.
Denise R. Sutherland, Esq.GOODMAN NEUMAN HAMILTON LLP41 7 Montgomery Street, 10th FloorSan Francisco, CA 94104(41 5) 705-0400; Fax: (415) 705-041 [email protected]@gnhllp.comAttorneys for Joseph J. Albanese, Inc.
Chad S. Tapp
PORTER SCOTT350 University Ave., #200
Sacramento, CA 95825Tel: (916)929-1481 /Fax: (916) [email protected] for Pacific Coast BuildingProducts dba Anderson Truss
G. Geoffrey Wood, Esq.
ERICKSEN, ARBUTHNOT155 Grand Avenue, Suite 1050
Oakland, CA 94612(5 1 0) 832-7770 ext 1 1 6; Fax: (5 1 0) 832-0 1 [email protected] for Dimetrius Painting II, Inc.
Thomas R. Kirvin, Esq.LAW OFFICES OF HELEN SANTANA71 Stevenson Street, Suite 700San Francisco, CA 94105
(415) 777-1308; Fax; (415) 896-9063
[email protected] for Intervener Liberty Mutual Ininsured California Classic Paver Designs
David M. Levy
VAN DE POEL, LEVY & ALLEN, LLP1600 South Main Plaza, Suite 325Walnut Creek, CA 94596(925) 934-6102; Fax: (925) [email protected] for LDI Mechanical, Inc.; EasternLandscape Company, Inc.
Brian H. Gunn, Esq.
Rebecca J. Collaco, Esq.
WOLFE & WYMAN LLP2175 N. California Blvd., Suite 645Walnut Creek, CA 94596-3502(925) 280-0004; Fax: (925) [email protected] col 1 aco@wo 1 fewyman.comAttorneys for Alliance Building Products,Inc.
Marcia A. Pollioni, Esq.
Joseph A. Long, Esq.
LONG BLUMBERG, LLP2950 Buskirk Avenue, Suite 3 1 5Walnut Creek, California 94597(925) 941-0090; Fax: (925) 941-0085Cell: (415) 730-0072
[email protected]@longblumberg.comAttorneys for Los Nietos Construction
Michael J. Estep, Esq.LAW OFFICES OF TIMOTHY R.WAGNER
1655 Grant Street, Suite 800-BConcord, CA 94520
(925) 681-3600; Fax: (866) [email protected] for Pyramid Builders, Inc. andDavey Roofing, Inc.
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Larry D, Letofsky, Esq.Robyn S. McCiain, Esq.
LETOFSKY MCCLAIN3655 Nobel Drive, Suite 400San Diego, CA [email protected]^[email protected](858) 642-1372; Fax: (858) 642-1379Attorneys for AMPAM ParksMechanical, Inc.
Samuel J. Muir, Esq.Stephen B. Litchfield, Esq.COLLINS COLLINS MUIR + STEWAR11 999 Harrison Street, Suite 1 700Oakland. CA 94612(5 1 0) 844-5 1 00: Fax: (5 1 0) 844-5 1 0 [email protected]@ccmslaw.comAttorneys for McLarland, Vasquez &Partners, Inc.
Philip T. Bazzano, Esq.SELLAR HAZARD & LUCIA201 N. Civic Dr., Suite 145Walnut Creek, CA 94596(925) 938-1430; Fax: (925) [email protected] for Madera Construction
Thomas Yen, Esq.LAW OFFICE OF BEVERLY E.NARAYAN
525 Market St., Suite 2850San Francisco, CA 94105(415) 227-2300
Attorneys for Casey-Fogli ConcreteContractors, Inc.
Brett L. McKague, Esq.FLESHER MCKAGUE2202 Plaza Drive
Rockiin, CA 95765(916) 358-9042 / (916) 673-9672Attorneys for Gentry AssociatesConstruction Consultants
Joseph D. Ryan, Esq.Jill J. Lifter, Esq.
RYAN & LIFTER, APC2000 Crow Canyon Place, Suite 400San Ramon, CA 94583
(925) 884-2080; Fax: (925) [email protected]@rallaw.comAttorneys for Cell-Crete Corporation
Daniel A. Serot, Esq.VAN DE POEL, LEVY & ALLEN, LLP1600 South Main Plaza, Suite 325Walnut Creek, CA 94596(925) 934-6102; Fax: (925) [email protected]
Attorneys for ADM Painting Company;ADM Construction Co., Inc.
Robert B. Lueck, Esq.Alexander R. Moore, Esq.
John A. Castro, Esq.BOORNAZIAN, JENSEN & GARTHE555 12th Street, Suite 1800Oakland, CA 94607(510) 834-4350; Fax: (510) [email protected]
[email protected]@bjg.com
Attorneys for Madera Framing, Inc.
Geoffrey Kraemer, Esq.MORROW & WHITE
535 Anton Blvd., Suite 1 1 50Costa Mesa, CA 92626
(714) 979-7999 / (714) [email protected]@morrow-white.comAttorneys for ADM Construction Co., Inc.
Todd A. Fischer, Esq.Bryan P. Kerney, Esq.
FISCHER KERNEY888 Munras Avenue
Monterey, CA 93940(831) 372-9200/(831) [email protected]
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Steven W. Ferla, Esq.
MENEKSHE LAW Film
950 East Campbell AvenueCampbell, CA 95008
(408) 358-1200/(408) [email protected] for Cell-Crete Corporation
Elizabeth W. Lawley, Esq.HAIGHT BROWN & BONESTEEL
2485 Natomas Park Dr., Suite 450Sacramento, CA 95833
(916) 702-3200/(916) [email protected]
Attorneys for Madera Framing, Inc.
[email protected],corn
Attorneys for Pyramid Builders, Inc.
Frank J. Perretta, Esq.
MILLER MORTION CAILLAT & NEVIS50 West San Fernando St., Suite 1300
San Jose, CA 95113
(408) 292-1765 / (408) 436-8272
Attorneys for White Residential, Inc.