RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE

PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 1

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MAKE BELIEVE LAW GROUP
EVA C. TORRES, ESQ SBN 123456789
123 Green Street
Pasadena, California 91106
626.555.0000

Attorney for Plaintiff,
Tina Lee
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
Tina Lee, etc.; et al.,
Plaintiff,
vs.
RITE AID CORPORATION, etc.; et al.,
Defendants
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Case No.: BC5568897
Assigned to the Hon. David Milton,
Department NC-D
RESPONSES OF PLAINTIFF TINA LEE
TO FORM INTERROGATORIES, SET
ONE PROPOUNDED BY DEFENDANT
RITE AID CORPORATION

PROPOUNDING PARTY : Defendant RITE AID CORPORATION
RESPONDING PARTY : Plaintiff TINA LEE
SET NUMBER : One

FORM INTERROGATORY NO. 1.1:
State the name, ADDRESS, telephone number, and relationship to
you of each PERSON who prepared or assisted in the preparation of the responses to
these interrogatories
RESPONSE TO FORM INTERROGATORY NO. 1.1:

RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE
PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 2
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Eva Torres
123 Green Street
Pasadena, California 91106
626-555-0000
Attorney

FORM INTERROGATORY NO. 2.1:
State:
a) your name;
b) every name you have used in the past; and
c) the dates you used each name.
RESPONSE TO FORM INTERROGATORY NO. 2.1:
a) Tina Lee
b) Tina Lee. Birth name January 1990 to present
c) Tina Lee. Birth name January 1990 to present
FORM INTERROGATORY NO. 2.2:
State the date and place of your birth.
RESPONSE TO FORM INTERROCATORY NO. 2.2:
January 18, 1990, Los Angeles, California
FORM INTERROGATORY NO. 2.6:
State:
a) The name, ADDRESS, and telephone number of your present employer or
place of self-employment, and

RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE
PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 3
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b) The name, ADDRESS, and dates of employment, job title, and nature of
work for each employer or self-employment you have had from five years
before the INCIDENT until today.
RESPONE TO FORM INTERROGATORY 2.6:
a) Unemployed
b) Has never been employed nor self-employed.
FORM INTERROGATORY 2.7:
State:
a) The name and ADDRESS of each school or other academic or vocational
institution you have attended, beginning with high school;
b) The dates you attended
c) The highest grade level you have completed; and
d) The degrees received.
RESPONSE TO FROM INTERROGATORY 2.7:
a) Lincoln High School, 5458 South Mariposa Avenue, Los Angeles,
California 90012, University of California Santa Barbara, 6321 North
Madison Road, Santa Barbara 94156.
b) Lincoln High School( 2004-2008); University of California Santa
Barbara(2008-2012)
c) Lincoln High School, 12
th
grade, University of California Santa Barbara, 4
year Undergraduate.
d) Lincoln High School, High School Diploma; University of California Santa
Barbara, Bachelors Degree in Arts

RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE
PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 4
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FORM INTERROGATORY NO. 2.9:
Can you speak English with ease? If not, what language and dialect do you
normally use?
RESPONSE TO FORM INERROGATORY 2.9:
Yes, I am able to speak English with ease.
FORM INTERROGATORY NO. 2.10:
Can you read and write with ease? If not, what language and dialect do you
normally use?
RESPONSE TO FORM INERROGATORY 2.10:
Yes, I am able to read and write in English with ease.





Dated this 1 of February, 2014
Eva C. Torres






RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE
PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 5
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VERIFICATION
I, Tina Lee, declare as follows:

1. I am a defendant in the instant litigation.
2. I have read the answers to Defendants responses to Plaintiffs Form
Interrogatories, Set One and know of their contents.
3. I verify the truth of said responses or believe them to be true to the best of
my knowledge.


I declare under penalty of perjury of the laws of the State of California that
foregoing is true and correct.


Date: _______________
By____________________











RESPONSES OF PLAINTIFF TINA LEE TO FORM INTERROGATORIES, SET ONE
PROPOUNDED BY DEFENDANT RITE AID CORPORATION - 6
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PROOF OF SERVICE
(STATE OF CALIFORNIA, COUNTY OF LOS ANGELES)

I am employed in the County of Los Angeles, State of California. I am over the
age of eighteen (18) and not a party to the within action; my business address is 1100
E. Green Street, Pasadena, California 91106-2513.

On February 1, 2014, I served the foregoing document described as
RESPONSES OF PLAINTIFF, TINA LEE, FORM INTERROGATORIES PROPUNDED
BY DEFENDANT RITE AID CORPORATION., on all interested parties in this action by
placing a true copy thereof enclosed in a sealed envelope as follows:

Name of other lawyer
Address of other lawyer
Attorney for Defendant, RITE AID CORPORATION


_X_I am readily familiar with the firms practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the U. S
Postal Service on that same day with postage thereon fully prepaid at Pasadena,
California, in the ordinary courses of business.

__ (By Mail) I caused such envelope with postage thereon fully prepaid to be
placed in the United States mail at Pasadena, California.

__ (By Fax) I caused such document to be faxed at Pasadena, California. A copy
of the facsimile transmission sheet is attached hereto.

__ (By personal Service) I caused such envelope to be delivered by hand to the
addresses(s).

__ (State) I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.

Executed on February 1, 2014, at Pasadena, California.

Eva Torres, Paralegal