To: Paralegal

From: Renato L. Izquieta

Subject: Assignment 1- Special interrogatories


John Smith filed a personal injury and other causes of action against his landlord, Tom Roberts, for injuries he sustained in his apartment. The facts of the case are as follows:

John Smith went to "Jack’s Fast Food” and purchased a meal to take back home. John Smith set the bag of food on the floor in the middle of his living room. He then went into his bedroom get blanket because he was going to sit on the floor to eat his meal and watch television. While in his bedroom he heard a hard banging and pounding on his door. This startled John Smith. He dashed out of his room through his living 

room to investigate why someone was feverishly banging on his door.  In doing so, he tripped over his bag of food which caused him to slide 

across his floor and crash through the side window panel next to the front door. He went through the glass head first. John Smith sustained 

several deep lacerations to his face and neck. John Smith was taken by ambulance to the hospital. Many of his lacerations required stitches. 

Some of his scars will be permanent.

As a result, John Smith filed a lawsuit against Tom Roberts, the owner of the apartment building. The suit was filed in the Superior Court, 

County of Orange, Central Justice Center, Case No. 22C10000. John is suing for $50,000 in compensatory and other damages. Part of his 

lawsuit alleges negligence against the landlord, Tom Roberts, for not providing a safe dwelling. Defendant, Tom Roberts, timely filed an 

answer with the court. The defendant is represented by, Chris Ruppert, Esq. Opposing counsel’s address is 4673 Main Irvine, CA 92602

Please prepare a minimum of 10 Special Interrogatories against the defendant, Tom Roberts. You must also include a proof of service by mail.

These are the first set of Interrogatories. No other discovery has been propounded to date. Use the samples and template which I’ve provided as a guide and tool.

My caption must be typed as follows:

Renato L. Izquieta, SBN 192776

Attorney at Law

2101 N. Tustin Ave.

Santa Ana, CA 92705

(714) 571-5258

(714) 571-5270 Fax

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