United States District Court for the Washington District of Utah
| Sylbia Sebastian, Plaintiff vs. Brand New Pharmaceuticals, Defendant | Case No. 123456789 |
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
Pursuant to Fed. R. Civ. P. 33, the Plaintiff, Sylbia Sebastian, requests that the Defendant answers, in writing under oath, the following Interrogatories within thirty (30) days of the service. The Plaintiff requests that the Defendant serve its answers to the undersigned counsel for Plaintiff at 970 Sage Dr. #109, Cedar City, Utah 84720.
Definitions
- “You” or “Your” refers to Brand New Pharmaceuticals, its officers, directors, employees, agents, representatives, attorneys, and any other individuals or entities acting on behalf of Brand New Pharmaceuticals.
- “Possession, Custody, or Control” includes, but is not limited to, documents physically held by You, documents stored in Your electronic or digital systems, and documents held by Your staff, agents, employees, representatives, and attorneys, or any other individuals or entities under Your direction or supervision.
Instructions
- These interrogatories refer to the circumstances of the occurrence mentioned in the pleadings.
- When the identity of a person is requested, please state the full legal name and address
- Wherever knowledge, information, or documents are sought, this request includes those within your possession, custody, or control, or within the possession, custody, or control of your staff, agents, employees, representatives, and, unless privileged, attorneys, or any other individual with possession, custody, or control of your proprietary knowledge, information, or documents
Interrogatories
- Identify all individuals who participated in the design, development, testing, manufacturing, marketing, distribution, or sale of the WHIZ-KID ovulation support device.
- Provide a detailed description of the process involved in the design, development, testing, manufacturing, marketing, distribution, and sale of the WHIZ-KID ovulation support device, including any quality control procedures implemented during these processes.
- Identify all documents, including but not limited to internal memos, emails, reports, studies, and communications, related to the safety, efficacy, and potential risks associated with the WHIZ-KID ovulation support device.
- Describe any complaints, adverse events, or reports of injuries or complications associated with the use of the WHIZ-KID ovulation support device that have been received by Brand New Pharmaceuticals.
- Provide all documents, including but not limited to instructions for use, warnings, labels, and packaging materials, accompanying the WHIZ-KID ovulation support device at the time of sale.
- Describe any testing, studies, or research conducted by or on behalf of Brand New Pharmaceuticals to assess the safety, efficacy, or potential risks associated with the WHIZ-KID ovulation support device.
- Describe any training, instructions, or educational materials provided to healthcare professionals, distributors, or retailers regarding the proper use, handling, or storage of the WHIZ-KID ovulation support device.
DATED this 18th day of April 2024.
/s/ Gisselle Y. Fajardo Reyes