LAW OFFICES OF GROUP ONE
State Bar No. 00000000
123 South Secondary Street
San Jose, CA 95333
Phone: 408-555-1212
Fax: 408-555-1234

Attorney for PLAINTIFF,
ANNE ANDERSON, for herself, and
as a Parent and Next Friend of CHARLES
ANDERSON, and as Administratrix
of the Estate of JAMES ANDERSON


SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA


ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON,

Plaintiff,

vs.

BEATRICE FOODS INC., A California Corporation,

Defendant.
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Case No.: 1234513789

PLAINTIFF ANNE ANDERSON’S RESPONSE TO DEFENDANT BEATRICE FOODS INC.’S SPECIAL INTERROGATORIES








DEMANDING PARTY: DEFENDANT, BEATRICE FOODS INC.

RESPONDING PARTY: PLAINTIFF, ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON

SET NUMBER: ONE (1)



Pursuant to California Code of Civil Procedure section 2030.210 et seq., Plaintiff, ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON (“Plaintiff”) hereby responds to the Special Interrogatories, Set One, of Defendant BEATRICE FOODS INC. (“Defendant”) as follows:
GENERAL RESPONSE
1. Plaintiff’s response to Defendant’s Special Interrogatories, Set One, is made to the best of Plaintiff’s present knowledge, information, and belief. Said responses are at all times subject to such additional or different information that discovery or further investigation may disclose and, while based on the present state of Plaintiff’s recollection and understanding, is subject to such refreshing of recollection, and such additional knowledge of facts, as may result from Plaintiff’s further discovery and investigation. Plaintiff reserves the right to make any use of, or to introduce at any hearing and at trial, information and/or documents responsive to Defendant’s Special Interrogatories, Set One discovered subsequent to the date of this response.
2. Plaintiff reserves all objections or other questions as to the competency, relevance, materiality, privilege or admissibility as evidence in any subsequent proceeding or in trial of this or any action for any purpose whatsoever of this response.
3. Plaintiff reserves the right to object on any ground at any time to such other or supplemental interrogatories as Defendant may at any time propound involving or relating to the subject matter of these interrogatories.
4. For interrogatories which ask Plaintiff to identify documents she relies upon, see documents bates labeled M00001 – M00543 produced in response to Defendant Actual Assets, Inc.’s Request For Production of Documents, Set One. (we more than like will need to delete this highlighted section but, just incase we come up with some sort of document for submittal, here is the correct verbiage) - Amanda
GENERAL OBJECTIONS
1. Plaintiff objects to the interrogatories in their entirety, and to each interrogatory contained therein, to the extent they seek information or production of documents protected by the attorney-client or the attorney work product privilege. Such information or production of documents is beyond the scope of discovery and shall not be disclosed in response to any of these interrogatories. Any inadvertent disclosure or production thereof shall not be deemed a waiver of any privilege with respect to such information or documents or of any work product doctrine which may attach thereto.
2. Plaintiff objects to this set of interrogatories, and to each interrogatory contained therein, on the ground they are overbroad and unduly burdensome. Discovery has only recently commenced in this matter. Plaintiff responds in light of information known to date or discoverable upon reasonable inquiry. Plaintiff reserves the right to amend and/or supplement these responses to reflect subsequently discovered facts or evidence, and/or to introduce such facts or evidence at trial or at any other appropriate time during this action.
3. Plaintiff objects to any interrogatory to the extent it seeks to require Plaintiff to search for information about documents no longer in existence or in Plaintiff’s possession, custody or control, on the grounds that said interrogatory is overly broad, would subject Plaintiff to undue annoyance, oppression, burden, and expense, and seeks to impose upon Plaintiff an obligation to investigate information or materials from third parties or sources who are equally accessible to Defendants.

RESPONSES TO SPEICAL INTERROGATORIES


Without waiving or limiting in any manner any of the foregoing General Objections, but rather incorporating them into each of the following responses to the extent applicable, Plaintiff responds to Defendant’s Special Interrogatories, Set One as follows:
_
CLASSMATES: NOTE
USE THIS OBJECTION IF YOU ARE GOING TO OBJECT, BUT ANSWER THE QUESTION.
OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. Without waiving any privilege, Complainant responds as follows:
_

SPECIAL INTERROGATORY 1:
State all facts that support the allegations contained in paragraph 8 of the complaint filed on 14 May 1982, herein after referred to as COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY NO. 1:
Plaintiff incorporates all General Objections. Plaintiff further objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, compound and not narrowly tailored to the issues in dispute. Plaintiff further objects to this Interrogatory on grounds that it calls for a legal conclusion and adds that this Interrogatory requests information subject to privilege, including attorney work product. Further, this discovery request seeks legal reasoning and theories of Plaintiff’s contentions. Plaintiff objects to this Interrogatory on the grounds that Plaintiff is not required to prepare the Defendant’s case. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and therefore the nature of the business operations at THE TANNERY is still being investigated. COMPLAINT does not state allegations but rather a duty of care owed to society according to Palsgraff v Long Island RailRoad Company, 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928).

SPECIAL INTERROGATORY 2:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 1.
RESPONSE TO SPECIAL INTERROGATORY 2:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on grounds that it calls for a legal conclusion and seeks legal reasoning and theories of Plaintiff’s contentions and adds that this Interrogatory requests information subject to privilege, including attorney work product. Plaintiff further objects to this Interrogatory on the basis that Plaintiff is not required to prepare the Defendant’s case. Lastly Plaintiff objects to this Interrogatory on the grounds that it contains subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).

SPECIAL INTERROGATORY 3:
Fully identify all documents in support of your response to INTERROGATORY 1.
RESPONSE TO SPECIAL INTERROGATORY 3:
Plaintiff incorporates all General Objections Plaintiff further objects to this interrogatory on grounds that it requests information subject to privilege, including attorney work product. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: COMPLAINT does not state allegations but rather a duty of care owed to society according to Palsgraff v Long Island RailRoad Company, 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928).
SPECIAL INTERROGATORY 4:
State all facts that support the allegations contained in paragraph 9 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 4:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 5:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 4.
RESPONSE TO SPECIAL INTERROGATORY 5:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).

SPECIAL INTERROGATORY 6:
Fully identify all documents in support of your response to INTERROGATORY 4.
RESPONSE TO SPECIAL INTERROGATORY 6:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 7:
State all facts that support the allegations contained in paragraph 10 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 7:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on grounds that it calls for a legal conclusion and adds that this Interrogatory requests information subject to privilege, including attorney work product. Further, this discovery request seeks legal reasoning and theories of Plaintiff’s contentions. Plaintiff is not required to prepare the defendant’s case. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and therefore the standard business practices of BEATRICE FOODS CO is still yet to be determined. That aside, in 1978 Woburn police investigated the appearance of 184 barrels filled with waste on vacant land THE TANNERY owned resulting in wells G and H being tested whereupon TCE and PERC were found and the wells immediately shut down.

SPECIAL INTERROGATORY 8:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 7.
RESPONSE TO SPECIAL INTERROGATORY 8:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f). Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Gerald McCall, acting director for Northeast of State environmental department. 512 San Carlos Street, San Jose, CA 95512.

SPECIAL INTERROGATORY 9:
Fully identify all documents in support of your response to INTERROGATORY 7.
RESPONSE TO SPECIAL INTERROGATORY 9:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on grounds that it requests information subject to privilege, including attorney work product. Plaintiff is not required to prepare the defendant’s case. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and the location of all documents is not known at this time.

SPECIAL INTERROGATORY 10:
State all facts that support the allegations contained in paragraph 12 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 10:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it seeks premature disclosure of expert opinion in the violation of Code of Civil Procedure sections 2034.210, 2034.220, and 2034.270. The interrogatory also seeks attorney work-product in violation of Code of Civil Procedure sections 2018.020 and 2018.030. Plaintiff has not decided on which, if any, expert witnesses may be called at trial; insofar as this interrogatory seeks to ascertain the identity, writings, and opinions of Plaintiff’s experts who have been retained or utilized to date solely as an advisor or consultant, is a violation of the work-product privilege.

SPECIAL INTERROGATORY 11:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 10.
RESPONSE TO SPECIAL INTERROGATORY 11:
Plaintiff incorporates all General Objections. Plaintiff further objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, compound and not narrowly tailored to the issues in dispute. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).

SPECIAL INTERROGATORY 12:
Fully identify all documents in support of your response to INTERROGATORY 10.
RESPONSE TO SPECIAL INTERROGATORY 12:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad, unduly burdensome, compound and not narrowly tailored to the issues in dispute. Plaintiff further objects to this interrogatory on grounds that it requests information subject to privilege, including attorney work product. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and the location of all documents is not known at this time.
SPECIAL INTERROGATORY 13:
State all facts that support the allegations contained in paragraph 13 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 13:

Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 14:


Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 13.
RESPONSE TO SPECIAL INTERROGATORY 14:
Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 15:
Fully identify all documents in support of your response to INTERROGATORY 13.
RESPONSE TO SPECIAL INTERROGATORY 15:
Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 16:
State all facts that support the allegations contained in paragraph 14 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 16:
Plaintiff incorporates all General Objections. The interrogatory seeks premature disclosure of expert opinion in violation of Code of Civil Procedure section 2034.210, 2034.220, and 2034.270. The interrogatory also seeks attorney work-product in violation of Code of Civil Procedure sections 2018.020 and 2018.030. Plaintiff has not decided on which, if any, expert witness may be called at trail; insofar as this interrogatory seeks to ascertain the identity, writings, and opinions of plaintiff’s experts who have been retained or utilized to date solely as an advisor or consultant, it is violated of the work-product privilege. (See South Tahoe Public Utilities District v. Superior Court (1979) 90 Cal.App.3d 135[154 Cal.Rptr. 1]; Sheets v. Superior Court(1967) 257 Cal.App.2d 1[64 Cal.Rptr.753]; and Sanders v. Superior Court, (1973) 34 Cal.App.3d 270 [109 Cal. Rptr. 770].) Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 17:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 16.
RESPONSE TO SPECIAL INTERROGATORY 17:
Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 18:
Fully identify all documents in support of your response to INTERROGATORY 16.
RESPONSE TO SPECIAL INTERROGATORY 18:
Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTEEOGATORY 19:
:State all facts that support the allegations contained in paragraph 15 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 19:
Plaintiff incorporates all General Objections. The interrogatory seeks premature disclosure of expert opinion in violation of Code of Civil Procedure section 2034.210, 2034.220, and 2034.270. The interrogatory also seeks attorney work-product in violation of Code of Civil Procedure sections 2018.020 and 2018.030. Plaintiff has not decided on which, if any, expert witness may be called at trail; insofar as this interrogatory seeks to ascertain the identity, writings, and opinions of plaintiff’s experts who have been retained or utilized to date solely as an advisor or consultant, it is violated of the work-product privilege. (See South Tahoe Public Utilities District v. Superior Court (1979) 90 Cal.App.3d 135[154 Cal.Rptr. 1]; Sheets v. Superior Court(1967) 257 Cal.App.2d 1[64 Cal.Rptr.753]; and Sanders v. Superior Court, (1973) 34 Cal.App.3d 270 [109 Cal. Rptr. 770].) Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
SPECIAL INTERROGATORY 20:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 19.
RESPONSE TO SPECIAL INTERROGATORY 20:
Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Ann Anderson, Charles Anderson, Wolburn Water Department in California.
SPECIAL INTERRIGATORY 21:
Fully identify all documents in support of your response to INTERROGATORY 19.
RESPONSE TO SPECIAL INTERROGATORY 21:
Plaintiff further objects to this interrogatory on the basis that Plaintiff is not required to prepare the defendant’s case and this Interrogatory requests information is equally available to the propounding party.
ESPECIAL INTERROGATORY 22:
State all facts that support the allegations contained in paragragh 16 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 22:
Anne Anderson suffered from chronic abdominal pain, intestinal cramps, irritable colon, nausea, vomiting, and fatigue. In medical testing by Dr. Saul Cohen, Anne Anderson and others in her neighborhood were found to have irregular heartbeats. They were also found by Dr. Robert G. Feldman and his team of doctors to have problems with short-term memory and control, visual and spatial organization, and/or depression, and all had slow blink reflexes.
SPECIAL INTERROGATORY 23:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 22.
RESPONSE TO SPECIAL INTERROGATORY 23:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it seeks premature disclosure of expert opinion in the violation of Code of Civil Procedure sections 2034.210, 2034.220, and 2034.270. The interrogatory also seeks attorney work-product in violation of Code of Civil Procedure sections 2018.020 and 2018.030. Plaintiff has not decided on which, if any, expert witnesses may be called at trial; insofar as this interrogatory seeks to ascertain the identity, writings, and opinions of Plaintiff’s experts who have been retained or utilized to date solely as an adviser or consultant, is a violation of the work-product privilege.
SPECIAL INTERROGATORY 24:
Fully identify all documents in support of your response to INTERROGATORY 22.
RESPONSE TO SPECIAL INTERROGATORY 24:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad, unduly burdensome, compound and not narrowly tailored to the issues in dispute. Plaintiff further objects to this interrogatory on grounds that it requests information subject to privilege, including attorney work product. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and the location of all documents is not known at this time.
SPECIAL INTERROGATORY 25:
State all facts that support the allegations contained in paragraph 17 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 25:
Anne Anderson worked in a library prior to her marriage to Charles Anderson, and much of her time was spent caring for Jimmy and taking him to several doctor’s appointments for follow-up, therefore causing her to leave her job to manage added responsibilities.
SPECIAL INTERROGATORY 26:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 25.
RESPONSE TO SPECIAL INTERROGATORY 26:
Anne and Charles Anderson: 11 Orange Street in the City of Woburn, Santa Clara, CA.
Dr. John Truman: Chief of Pediatric Hematology at Massachusetts General Hospital

Anne's former employer: whose name is unknown at this time.

SPECIAL INTERROGATORY 27:
Fully identify all documents in support of your response to INTERROGATORY 25.
RESPONSE TO SPECIAL INTERROGATORY 27:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad, unduly burdensome, compound and not narrowly tailored to the issues in dispute. Plaintiff further objects to this interrogatory on grounds that it requests information subject to privilege, including attorney work product. Subject to and without waiving the foregoing general and specific objections, Plaintiff responds as follows: Discovery is ongoing and the location of all documents is not known at this time.
SPECIAL INTERROGATORY 28:
State all facts that support the allegations contained in paragraph 18 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 28:
Majority of Anne's time was spent taking care of Jimmy. Charles wanted to move for a job opportunity, but Anne believed the move would be too hard on the family considering Jimmy’s illness, therefore resulting in a disagreement. Additionally, before the wells were found to be contaminated, Anne and Charles' disagreement over whether the water was causing the leukemia added to their marital troubles.
SPECIAL INTERROGATORY 29:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 29.
RESPONSE TO SPECIAL INTERROGATORY 29:
Anne and Charles Anderson: See answer to INTERROGATORY NO. 26.
Reverend Bruce Young: UNKNOWN AT THIS TIME
SPECIAL INTERROGATORY 30:
Fully identify all documents in support of your response to INTERROGATORY 29.
RESONSE TO SPECIAL INTERROGATORY 30: No such documents exist.
SPECIAL INTERROGATORY 31:
State all facts that support the allegations contained in paragraph 19 of COMPLAINT.
RESPONSE TO SPECIAL INTERROGATORY 31:
The water contaminated by TCE and PERC ruined the dishwasher. The door corroded to such a degree that it had to be replaced. The prongs that hold the dishes just gave way and broke off. On a regular basis, the pipes under the kitchen sink would leak, and under the bathroom sink. The faucets had to be replaced. The bathroom faucet dripped constantly.
SPECIAL INTERROGATORY 32:
Fully identify all witnesses, including address and telephone number, having personal knowledge of your response to INTERROGATORY 31.
RESPONSE TO SPECIAL INTERROGATORY 32:
Anne and Charles Anderson: See answers to INTERROGATORIES 26 and 29.
The plumber: whose name is unknown at this time.
SPECIAL INTERROGATORY 33:
Fully identify all documents in support of your response to INTERROGATORY 31.
RESPONSE TO SPECIAL INTERROGATORY 33:
Enclosed are copies of plumbing bills and a recent property appraisal.
SPECIAL INTERROGATORY 34:
Have any of your parents, siblings, cousins, aunts, uncles, or grandparents, hereinafter referred to as EXTENDED FAMILY ever been diagnosed with cancer?
RESPONSE TO SPECIAL INTERROGATORY 34:
Plaintiff incorporates all General Objections. Plaintiff has no existing knowledge of said EXTENDED FAMILY HEALTH HISTORY. Plaintiff further objects to this interrogatory on the grounds that it is overly burdensome and oppressive.
SPECIAL INTERROGATORY 35:
If your response to INTERROGATORY 34 is in the affirmative, state facts relevant to your response, including the persons relationship to you, form of cancer, date of diagnosis and date of death (if applicable).
RESPONSE TO SPECIAL INTERROGATORY 35:
Objection. This discovery request has, in substance, been previously propounded. See INTERROGATORY 34. Continuous discovery into the same matter constitutes oppression, and Plaintiff further objects on that ground.
SPECIAL INTERROGATORY 36:
Was James Anderson, herein after referred to as YOUR SON, ever exposed to toxic substances including, but not limited to; harsh, abrasive household detergents, cleaning agents, and the product Drano®?
RESPONSE TO SPECIAL INTERROGATORY 36:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).
SPECIAL INTERROGATORY 37:
If your response to INTERROGATORY 36 is in the affirmative, state facts relevant to your response; including date of exposure, chemical exposed to and action taken.
RESPONSE TO SPECIAL INTERROGATORY 37:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).
SPECIAL INTERROGATORY 38:
Between 1960 and the present, herein after referred to as RELEVANT DATES, how often do you use a fireplace or wood–burning stove in your home?
RESPONSE TO SPECIAL INTERROGATORY 38:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).
SPECIAL INTERROGATORY 39:
Has YOUR SON ever been exposed to ash, smoke or any other bi-products of a fire?
RESPONSE TO SPECIAL INTERROGATORY 39:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f).
SPECIAL INTERROGATORY 40:
If your response to INTERROGATORY 39 is in the affirmative, identify details of the exposure; including product exposed to, date of exposure, amount of exposure and action taken.
RESPONSE TO SPECIAL INTERROGATORY 40:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that subparts, or a compound, conjunctive, or disjunctive question in violation of Code of Civil Procedure section 2030.060 subdivision (f). Plaintiff further objects to this interrogatory on the grounds that it is overly burdensome and oppressive.
SPECIAL INTERROGATORY 41:
Were you exposed to x-radiation from a radiography for any medical condition(s) prior to your pregnancy with YOUR SON?
RESPONSE TO SPECIAL INTERROGATORY 41:
Plaintiff has no existing knowledge of x-radiation exposure.
SPECIAL INTERROGATORY 42:
If your response to INTERROGATORY 41 is in the affirmative, state facts relevant to your response; including date and part of body x-rayed.
RESPONSE TO SPECIAL INTERROGATORY 42:
Objection. This discovery request has, in substance, been previously propounded. See INTERROGATORY 41. Continuous discovery into the same matter constitutes oppression, and Plaintiff further objects on that ground.
SPECIAL INTERROGATORY 43:
Does YOUR SON have any allergies?
RESPONSE TO SPECIAL INTERROGATORY 43:
Objection. This Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 44:
If your response to INTERROGATORY 43 is in the affirmative, state facts relevant to your response; including type of allergy, date of allergy onset and date of last outbreak.
RESPONSE TO SPECIAL INTERROGATORY 44:
Objection. This discovery request has, in substance, been previously propounded. See INTERROGATORY 43. Continuous discovery into the same matter constitutes oppression, and Plaintiff further objects on that ground.
SPECIAL INTERROGATORY 45:
Describe any physical exercise routine you engaged in on a regular basis during the RELEVANT DATES; including type of exercise, duration and regularity.
RESPONSE TO SPECIAL INTERROGATORY 45:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is overbroad, requests irrelevant and immaterial information. Plaintiff further objects to this interrogatory on the grounds of relevance.
SPECIAL INTERROGATORY 46:
How often did you consume alcohol during the RELEVANT DATES?
RESPONSE TO SPECIAL INTERROGATORY 46:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that s is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Plaintiff further objects to this interrogatory on the grounds of relevance to the subject matter; and is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 47:
Describe your relationship with your husband.
RESPONSE TO SPECIAL INTERROGATORY 47:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Plaintiff further objects to this interrogatory on the grounds of relevance to the subject matter; and is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 48:
Describe your relationship with YOUR SON.
RESPONSE TO SPECIAL INTERROGATORY 48:
Plaintiff incorporates all general objections. The Plaintiff further objects on the grounds of her right to privacy. The relationship between the Plaintiff and her son speaks for itself and there is no need for further elaboration. Plaintiff further objects to this interrogatory on the grounds that it is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Plaintiff further objects to this interrogatory that it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 49:
Was your son ever bullied?
RESPONSE TO SPECIAL INTERROGATORY 49:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Plaintiff further objects to this interrogatory as it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 50:
If your response to INTERROGATORY 49 is in the affirmative, describe each instance; including when, by whom and any injuries suffered as a result.
RESPONSE TO SPECIAL INTERROGATORY 50:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Plaintiff further objects to this interrogatory as it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence.
SPECIAL INTERROGATORY 51:
Has your residence ever been exposed to lead or lead-based paint?
RESPONSE TO SPECIAL INTERROGATORY 51:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence, with attempts to extend the scope of discovery.
SPECIAL INTERROGATORY 52:
If your response to INTERROGATORY 51 is in the affirmative, state facts relevant to your response; such as when the exposure was discovered, duration of the exposure and any action taken.
RESPONSE TO SPECIAL INTERROGATORY 52:
Plaintiff incorporates all general objections. Plaintiff further objects to this interrogatory on the grounds that it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects to this interrogatory on the grounds that it is overly burdensome and oppressive.
SPECIAL INTERROGATORY 53:
Has lead abatement ever been performed at your residence?
RESPONSE TO SPECIAL INTERROGATORY 54:
Plaintiff incorporates all General Objections. Plaintiff has no existing knowledge of said performance. Plaintiff further objects to this interrogatory on the grounds that it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects to this interrogatory on the grounds that it is overly burdensome and oppressive.
SPECIAL INTERROGATORY 54:
If your response to INTERROGATORY 53 is in the affirmative, please describe the abatement; including who performed the service and when.
RESPONSE TO SPECIAL INTERROGATORY 54:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the grounds that it is vague and ambiguous, that it calls for the production of non-existent information/documentation, which if existed, would be irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome, to the extent that it calls for the production of documents in the format as they may be maintained in files outside of the principal investigatory and case files.
SPECIAL INTERROGATORY 55:
Has YOUR SON ever ingested non-food substances?
RESPONSE TO SPECIAL INTERROGATORY 55:
Plaintiff incorporates all General Objections. Plaintiff has no existing recollection or current knowledge of said “substance.” Plaintiff further objects on the grounds of relevance. The interrogatory is vague and ambiguous, that it calls for an explanation that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome.
SPECIAL INTERROGATORY 56:
If your response to INTERROGATORY 55 is in the affirmative, state facts relevant to your response; including what, how much and when.
RESPONSE TO SPECIAL INTERROGATORY 56:
Plaintiff incorporates all General Objections. Plaintiff has no existing knowledge of said “knowledge/facts”. Plaintiff further objects to this interrogatory on the grounds that it is not relevant to the subject matter of the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff further objects to this interrogatory on the grounds that it is overly burdensome and oppressive.
SPECIAL INTERROGATORY 57:
Was your residence ever equipped with asbestos covered piping?
RESPONSE TO SPECIAL INTERROGATORY 57:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad and oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule.
SPECIAL INTERROGATORY 58:
If your response to INTERROGATORY 59 is in the affirmative, state facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 58:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad and oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule.
SPECIAL INTERROGATORY 59:
Was your residence ever treated for termites?
RESPONSE TO SPECIAL INTERROGATORY 59:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad and oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule.
SPECIAL INTERROGATORY 60:
If your response to INTERROGATORY 59 is in the affirmative, state facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 60:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is overly broad and oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule.
SPECIAL INTERROGATORY 61:
Do you contend that any of the exposures you affirmed to thus far could have contributed to YOUR SON’s proclaimed illness?
RESPONSE TO SPECIAL INTERROGATORY 61:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it seeks the legal reasoning and theories of plaintiff's contentions and is not required to prepare the defendant's case.
SPECIAL INTERROGATORY 62:
How far along was your pregnancy when you found out you were pregnant with YOUR SON?
RESPONSE TO SPECIAL INTERROGATORY 62:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule. Plaintiff further objects that this interrogatory is an invasion of plaintiff's right to privacy. Plaintiff further objects to this interrogatory on the grounds that it seeks to discover plaintiff's medical history and/or treatment which is completely unrelated to the issue in this litigation in violation of plaintiff's constitutionally protected right to privacy under Article I, Section I of the California Constitution.
SPECIAL INTERROGATORY 63:
Did you consume alcohol at any time during your pregnancy with YOUR SON?
RESPONSE TO SPECIAL INTERROGATORY 63:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule. Plaintiff further objects that this interrogatory is an invasion of plaintiff's right to privacy.
SPECIAL INTERROGATORY 64:
If your response to INTERROGATORY 63 is in the affirmative, state all facts relevant to your response; including amount and frequency.
RESPONSE TO SPECIAL INTERROGATORY 64:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the basis that it is oppressive as to be an unwarranted annoyance. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule. Plaintiff further objects that this interrogatory is an invasion of plaintiff's right to privacy.
SPECIAL INTERROGATORY 65:
Did you take any medications at any time during your pregnancy with YOUR SON?
RESPONSE TO SPECIAL INTERROGATORY 65:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule. Plaintiff further objects that this interrogatory is an invasion of plaintiff's right to privacy. Plaintiff further objects to this interrogatory on the grounds that it seeks to discover plaintiff's medical history and/or treatment which is completely unrelated to the issue in this litigation in violation of plaintiff's constitutionally protected right to privacy under Article I, Section I of the California Constitution.
SPECIAL INTERROGATORY 66:
If your response to INTERROGATORY 65 is in the affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 66:
Plaintiff incorporates all General Objections. Plaintiff further objects to this interrogatory on the grounds that it exceeds permissible scope of discovery. Plaintiff further objects to this interrogatory seeks information not relevant to the subject matter of this lawsuit and not calculated to lead to the discovery of admissible evidence in violation of the collateral source rule. Plaintiff further objects that this interrogatory is an invasion of plaintiff's right to privacy. Plaintiff further objects to this interrogatory on the grounds that it seeks to discover plaintiff's medical history and/or treatment which is completely unrelated to the issue in this litigation in violation of plaintiff's constitutionally protected right to privacy under Article I, Section I of the California Constitution.
SPECIAL INTERROGATORY 67:
Have you ever used any tobacco products?
RESPONSE TO SPECIAL INTERROGATORY 67:

SPECIAL INTERROGATORY 68:
If your response to INTERROGATORY 67 is affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 68:

SPECIAL INTERROGATORY 69:
Have you ever used birth control?
RESPONSE TO SPECIAL INTERROGATORY 70:

SPECIAL INTERROGATORY 70:
If your response to INTERROGATORY 69 is in the affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 70:

SPECIAL INTERROGATORY 71:
Have you ever had a sexually transmittable disease (STD)?
RESPONSE TO SPECIAL INTERROGATORY 71:

SPECIAL INTERROGATORY 72:
If your response to INTERROGATORY 71 is in the affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 72:

SPECIAL INTERROGATORY 73:
Did you work in your yard during your pregnancy with YOUR SON?
RESPONSE TO SPECIAL INTERROGATORY 73:

SPECIAL INTERROGATORY 74:
If your response to INTERROGATORY 73 is in the affirmative, did you use snail bait?
RESPONSE TO SPECIAL INTERROGATORY 74:

SPECIAL INTERROGATORY 75:
If your response to INTERROGATORY 74 is in the affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 75:

SPECIAL INTERROGATORY 76:
If your response to INTERROGATORY 73 is in the affirmative, did you use fertilizers?
RESPONSE TO SPECIAL INTERROGATORY 76:

SPECIAL INTERROGATORY 77:
If your response to INTERROGATORY 76 is in the affirmative, state all facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 77:

SPECIAL INTERROGATORY 78:
Do you contend that the water at your residence is provided through Wells G and H?
RESPONSE TO SPECIAL INTERROGATORY 79:

SPECIAL INTERROGATORY 79:
During the RELEVANT DATES, how much tap water did your household consume on a monthly basis?
RESPONSE TO SPECIAL INTERROGATORY 79:

SPECIAL INTERROGATORY 80:
During the RELEVANT DATES, did your family exclusively consume tap water?
RESPONSE TO SPECIAL INTERROGATORY 80:

SPECIAL INTERROGATORY 81:
If your response to INTERROGATORY 80 is in the negative, state facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 81:

SPECIAL INTERROGATORY 82:
During the RELEVANT DATES, for what other reasons did your household utilize the tap water?
RESPONSE TO SPECIAL INTERROGATORY 83:

SPECIAL INTERROGATORY 83:
Were you ever made aware of the quality of your tap water during the RELEVANT DATES?
RESPONSE TO SPECIAL INTERROGATORY 83:

SPECIAL INTERROGATORY 84:
If your response to INTERROGATORY 83 is in the affirmative, state facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 84:

SPECIAL INTERROGATORY 85:
Did you ever store your tap water for later use?
RESPONSE TO SPECIAL INTERROGATORY 85:

SPECIAL INTERROGATORY 86:
If your response to INTERROGATORY 85 is in the affirmative, state facts relevant to your response.
RESPONSE TO SPECIAL INTERROGATORY 86:



Dated: April 19, 1982
AMANDA HALL
Attorney for PLAINTIFF
ANNE ANDERSON, for herself, and
as a Parent and Next Friend of CHARLES
ANDERSON, and as Administratrix
of the Estate of JAMES ANDERSON




PROOF OF SERVICE

I am employed in the City of San Jose, County of Santa Clara, California. I am over the age of 18 and not a party to the within action. My business address is LAW OFFICES OF GROUP ONE, 123 South Secondary Street, San Jose, CA 95333.
On April 26, 1982, I served a copy of the below-listed document(s) described as:
PLAINTIFF’S RESPONSE TO DEFENDANT BEATRICE FOODS INC.’S FIRST SET OF SPECIAL INTERROGATORIES

¨ BY U.S. MAIL: I enclosed the document(s) listed above in a sealed envelope or package, addressed to the person(s) at the address(es) set forth above and placed the envelope or package for collection and mailing, following this firm’s ordinary business practices. I am readily familiar with this firm’s practice for collecting and processing of documents for mailing. Under that practice, on the same day that document(s) is/are placed for collection and mailing, it/they is/are deposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope or package with postage fully prepaid.
¨ BY FAX TRANSMISSION: I faxed the document(s) to the persons at the fax numbers listed above. No error was reported by the fax machine that I used. A copy of the record of the fax transmission containing the time, date, and sending fax machine telephone number, which I printed out, is available upon request.
¨ BY HAND-DELIVERY: I served the document(s) by placing it/them in an envelope or package addressed to the persons at the addresses listed above and providing them to a professional messenger service for service. A copy of the professional messenger’s proof of delivery is available upon request.
þ BY E-MAIL: I caused the document(s) to be served electronically on the persons at the electronic notification addresses listed below.
¨ BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier.





I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on April 26, 1982, at San Jose, California.



Amanda Hall