COMES NOW Plaintiff and propounds the following interrogatories to Defendant [redacted] (“Defendant”) to be answered separately and fully in writing, under oath, as required by law.

INTERROGATORIES

1. Identify all employee(s) and/or agent(s) engaged in marketing and advertising on behalf of Defendant from January 1, 2012 to the present, including but not limited to, drafting and editing marketing and advertising materials (either hard copy or digital); providing tours of the facility; and responding to requests for information submitted via the internet, telephone, or in person. Include in your answer the last known telephone number and address of each employee(s) and/or agent(s).

ANSWER:

2. Identify who has been responsible from January 1, 2012 to the present for the hiring and supervision of all employee(s) and/or agent(s) engaged in marketing and advertising on behalf of Defendant, including but not limited to, drafting and editing marketing and advertising materials (either hard copy or digital); providing tours of the facility; and responding to requests for information submitted via the internet, telephone, or in person. Include in your answer the last known telephone number and address of each employee(s) and/or agent(s).

ANSWER:

3. Describe Defendant’s policies and procedures for the hiring of all employee(s) and/or agent(s) engaged in marketing and advertising on behalf of Defendant, including but not limited to, drafting and editing marketing and advertising materials (either hard copy or digital); providing tours of the facility; and responding to requests for information submitted via the internet, telephone, or in person.

ANSWER:

4. Identify the names and job titles of all persons who have/had the responsibility of formulating the policies and procedures for the hiring of all employee(s) and/or agent(s) engaged in marketing and advertising on behalf of Defendant from January 1, 2012 to the present, including but not limited to, drafting and editing marketing and advertising materials (either hard copy or digital); providing tours of the facility; and responding to requests for information submitted via the internet, telephone, or in person. Include in your answer the last known telephone number and address of each employee(s) and/or agent(s).

ANSWER:

5. Describe how Defendant monitored or supervised its employee(s) and/or agent(s) engaged in marketing and advertising on behalf of Defendant from January 1, 2012 to the present, including but not limited to, drafting and editing marketing and advertising materials (either hard copy or digital); providing tours of the facility; and responding to requests for information submitted via the internet, telephone, or in person.

ANSWER:

6. List each reprimand, action, complaint, or discovery actions taken against Defendant for its marketing or advertising practices by any local, state and/or federal entity.

ANSWER:

7. Describe the substance of any and all correspondence, conversation or communication Defendant’s employee(s) and/or agent(s) had with Plaintiff, her agent(s) and/or family members prior to June 20, 2012, concerning the services offered by your facility. Include in your answer, with whom, where when and the substance of any such communication, correspondence, or conversation.

ANSWER:

8. Identify each employee(s) and/or agent(s) of Defendant who had contact with Plaintiff, her agent(s) and/or family members prior to June 20, 2012, including but not limited to, providing a tour or responding to questions or requests for information either in persona, via the telephone, or through the internet. Include in your answer the last known telephone number and address of each employee(s) and/or agent(s).

ANSWER:

9. Identify each piece of informational, marketing, and/or advertising materials provided to Plaintiff, her agent(s) and/or family members prior to June 20, 2012.

ANSWER:

10. Identify any tour Defendant gave of its facility to Plaintiff, her agent(s) and/or family members prior to June 20, 2012. Include in your answer the date and time of any tour; all persons on the tour; and the last known telephone number and address of Defendant’s representative(s) on the tour.

ANSWER:

11. Identify any “request for information” submitted via the telephone, in person, or the internet by Plaintiff, her agent(s) and/or family members prior to June 20, 2012.

ANSWER:

12. Describe the substance of Defendant’s response to any “request for information” submitted via the telephone, in person, or the internet by Plaintiff, her agent(s) and/or family members prior to June 20, 2012.

ANSWER:

13. Identify each employee(s) and/or agent(s) of Defendant who either have any knowledge of, or witnessed, the execution of any document by Plaintiff, her agent(s) and/or family members prior to June 20, 2012. Include in your answer the last known telephone number and address of each employee(s) and/or agent(s).

ANSWER:

14. Please describe the qualifications of Defendant’s staff members, who would have comprised the “expert team” responsible for providing support and assistance to Plaintiff when she needed it during her residency at [redacted].

ANSWER: