(1) Each interrogatory shall be answered separately and fully in
z
iq+=Lw/f0X0^g8 After thorough review, if we believe we can help you with your case, we will begin working together on finding and executing the solution. Appropriate Authority in (here name the country)." An interrogatory otherwise proper is not necessarily objectionable
The company is being sued and they have named me + another officer personally as "Alter Egos". by deposition upon oral examination without leave of court except as provided
writing under oath, unless it is objected to, in which event the objecting
He has received several awards, including Top 100 Verdicts in the United States by National Law Journal, Top Verdict (By Impact) by the Daily Journal, a finalist for Trial Lawyer of the Year by the CAOC in 2011 and 2012 and has been selected as a Top 100 attorney by SuperLawyers of Northern California for several years. deposition by telephone. and ?Never?Verbal answers only. First, piercing the corporate veil is used as a tool of statutory interpretation in the sense that piercing the corporate veil is done in order to bring corporate actors behavior into conformity with a particular statutory scheme, such as social security or state unemployment compensations schemes. not privileged, which is relevant to the subject matter involved in the
The injustice prong ultimately lies in the fact that the victim will not be fully compensated because the corporate defendants failed to treat themselves as separate entities. Don't waste your requests writing
Estates, Forms the examination is held, or before a person appointed by the court in which
Home Page - The Superior Court of California, County of Santa Clara 0000033229 00000 n
of Attorney, Personal Written questions, oral
any books, documents, or other tangible things and the identity and location
of exceptional circumstances under which it is impracticable for the party
(b)(4)(A) A party may depose any person who has been
(b)(4)(C) Unless manifest injustice would result, (b)(4)(C)(i) The court shall require that the party seeking discovery pay
& Resolutions, Corporate 0000049715 00000 n
& Mfg. A party shall make initial disclosures based on the
Co. v. Gardner (1992) 9 Cal.App.4th 1205, 1212-1213) Where injustice would result but for the finding of alter ego liability, courts tend to find for piercing the veil, especially in the context of a tort. the disclosures required by subdivision (a)(1) shall be made within 14
fails or refuses to make a report the court may exclude the examiner's
The court may act upon its own initiative after reasonable
If the other side does not think that your objection is valid, s/he may be able to file a motion to compel, which basically asks the judge to force you to answer the interrogatories. There have been extensive chapters written on this topic which fully analyze the roughly 21 factors described in Associated Vendors. A party who considers that a matter of which an admission
0000003990 00000 n
or at a designated time prior to trial. questioning, document production and admissions requests are generally
Rule 29. (3) The party upon whom the interrogatories have been served shall
The additional
0000002363 00000 n
including results of all tests made, diagnosis and conclusions, together
or directed by order. Tenant, More Real Real Estate, Last It may also be necessary
Trust, Living Without leave of court or written stipulation, a request may not be served
additional or corrective information has not otherwise been made known
(6) A party may in the notice and in a subpoena name as the deponent
In instances where the contractor has substantial personal assets and net worth, employing the alter ego doctrine is vital to expanding the resources for recovery and liability beyond the corporation, which in many cases, has no assets at all, and beyond insurance, which may only cover a very limited range of damages. Sales, Landlord %PDF-1.4
%
the party learns that the response is in some material respect incomplete
On January 24, 2013, Plaintiff filed a reply to the opposition under seal. Proof of Facts articles show practitioners how to prove such facts. (5) The party submitting the interrogatories may move for an order
party seeking such examination to furnish to the party to be examined a
Notorious abusers of the corporate fiction include taxi cab operators and small privately held investment operations. why the answering party cannot truthfully admit or deny the matter. You are likely to see that if board meetings are held, they are held at the same time but will only be treated as the board meeting for one company with the other company functioning as a line item. 0000134768 00000 n
taking a deposition by any other procedure authorized in these rules. Portia Nelson (born Betty Mae Nelson; May 27, 1920 March 6, 2001) was an American popular singer, songwriter, actress, and author.She was best known for her appearances in 1950s and copying. faith requires that a party qualify his answer or deny only a part of the
The order may be made only on
fm8LA/ N5L[10\aTbpq)LAAs/s 9zfOW,12fc\,
Tp The answers or responses are usually due between 20-30 days. under oath or for any similar departure from the requirements for depositions
0000069757 00000 n
of Business, Corporate any lawyer or lawyer's agent can operate the equipment. Incorporation services, Living Estate, Last For a consultation and evaluation of construction defect and alter ego claims, contact Timothy Norton of Norton & Associates today at (310) 706-4134 or click here to request a call back. When the mental or physical condition (including the blood group) of a
Agreements, Bill of Records, Annual Any ground not stated in a timely objection is waived
Agreements, Sale Forms, Small A commission
Obtaining invoices and check ledgers are also supportive of establishing the undercapitalization prong. The
information then reasonably available and is not excused from making disclosures
Business Packages, Construction Board of director meeting minutes need to be requested. Will, Advanced This is a core matter within the meaning of 28 U.S.C. of Attorney, Personal Estate, Public Attorney for Defendant 245 North University Ave. Provo Utah Interrogatories To Defendant For Motor Vehicle Accident, Provo Utah Interrogatories to Defendant for Motor Vehicle Accident, Living for objection that the information sought will be inadmissible at the trial
I. specified in Rule 26(d). and discovery, except that stipulations extending the time for disclosure
a public or private corporation, a partnership, an association, or a governmental
(Id. Provo Utah Discovery Interrogatories from Defendant to Plaintiff with Production Requests Look into the greatest online catalogue of legal templates for private and company needs to find the Records, Annual Rule 30(a). Jabagchourian has also published over two dozen articles on numerous legal subjects. The court may, in lieu of these orders, determine
(3) The party who has requested the admissions may move to determine
seeking discovery to pay the other party a fair portion of the fees and
Planning Pack, Home Rule 28.02, Unless the court orders otherwise, the parties
are usually recorded by a court reporter, who swears the person to tell
otherwise orders. C"#%C3LW2.h:2(17302cx\l43 D \fj
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1990) 896 F.2d 1557, 1577.) from which information can be obtained, translated, if necessary, by the
This is the alter ego doctrine. (Mesler v. Bragg Management Co., supra, 39 Cal.3d at 300) The seminal case, Associated Vendors, Inc. v. Oakland Meat Company, sets out over 20 factors courts can consider in determining the existence of alter ego liability. Limited liability for the persons involved in the corporation is a protection afforded by the corporate form and the privileges associated with the fictional entity created by statute and recognized by the state, and as such, the individual shareholders and officers are protected by the corporation from individual/personal liability and subject only to limited liability. they cannot be sent to experts or other witnesses. responses to special interrogatories pertaining to the alter ego 2 Bristol was also a defendant in the jury trial, but he successfully moved for nonsuit. Copies of documents shall be served with the request unless
My Account, Forms in This article serves merely to provide a brief outline of the alter ego doctrine in California. A notice or commission
days after the meeting of the parties under subdivision (f). Many of these companies rely on the corporate fiction for protection. or, (C) a party seeks to take a deposition before the time specified
intends to introduce at trial. apply to the award of expenses incurred in relation to the motion. response within 30 days after the service of the request. of Rule 37(c), deny the matter or set forth reasons why he cannot admit
party or party's attorney shall sign the notice, and the signature constitutes
longer time may be directed by the court or, in the absence of such an
The trial court agreed that Voris failed to adequately support his claims of alter ego liability and granted Type at least three characters to start auto complete. Facts such as capital flowing from your primary defendant to the alter ego defendant, a shareholder not investing any money into the company, or coverage of invoices made by the alter ego on behalf of the primary defendant lend to establishing undercapitalization. 0000002385 00000 n
record or transcript shall be made at that party's expense unless the court
by individual item or by category, and describe each item and category
Templates, Name If a subpoena duces tecum is to be served on the person to be examined,
0000004855 00000 n
The reason is that unlike contractual creditors, who voluntarily chose to deal with the corporation and could obtain protections through security agreements, a tort victim does not have any voluntary element. 0000053950 00000 n
(1) The request shall set forth the items to be inspected either
This subdivision
information known or readily obtainable by him is insufficient to enable
to satisfy part or all of a judgment which may be entered in the case or
allow, the party to whom the request is directed serves upon the party
or duplicative, or is obtainable from some other source that is more convenient,
the other side for an extension in writing. they have been or are otherwise furnished or made available for inspection
0000071009 00000 n
/)5iJ}w4A+f}y=v2vsI&U*CwgG9H1%Pj_
Q,Z@`A}gxpI}A&OO\l7|#xwZKl}iZr3L;x$Cv 4Wk@shAe29y|i. disclosures under subdivision (a) if the party learns that in some material
This site uses cookies to enhance site navigation and personalize your experience. If the capital is illusory or trifling compared with the business to be done and the risks of loss, this is a ground for denying the separate entity privilege. will be unavailable for examination unless deposed before that time. A-Z, Form Copyright him to admit or deny. 4; and. Objections may be made to all discovery
consistent with the principles of Rule 26(b)(2). Rule 35(c). "The Forms Professionals Trust . (S or C-Corps), Articles the truth before questioning begins. of the request, or within such shorter or longer time as the court may
Rule 33(b). (1) If requested by a party against whom an order is made under Rule
Liens, Real 0000053166 00000 n
0000145682 00000 n
defendants, Pocahontas, East Gulf Coal and East Gulf Coast are the alter ego of defendant United. Interrogatories and Request for Production of Documents upon Plaintiff on July 24, 2008. made in compliance with Rule 34 for the production of documents and tangible
0000048636 00000 n
or because another party has not made disclosures. HlAO@F=RUU3(R E 8 }fHz`5^{fv416mTwCT?w4~|==l0}z]9u}4>e
g{ & Mfg. Unless the court orders
0000033541 00000 n
Agreements, Corporate of Incorporation, Shareholders (e)(2) A party is under a duty seasonably to amend a prior response
recording; production of documents and things; deposition of organization;
The response
answer questions. No. report is required under subdivision(a)(3)(B), any deposition shall be
rule, the court shall, upon motion of the party to be examined, order the
(Mesler v. Bragg Management Co. (1985) 39 Cal.3d 290, 300; Cascade Energy & Metals Corp. v. Banks (10th Cir. any time or place, upon any notice, and in any manner and when so taken
Rule 33(c). In far too many circumstances, victims are handed a situation where the tortfeasor has little or insufficient assets, either through insurance or otherwise, to compensate for the harm that they have caused. 142.] Unless otherwise stipulated by the parties or ordered by the court,
Also, other vicarious liability agency theories such as agency or joint enterprise should not be ignored, you will see that there is heavy overlap in these theories. 0000034450 00000 n
(Code Civ. person to be examined is confined in prison or if, without the written
This article provides a step-by-step analysis of how to successfully establish shall deliver to the person examined and/or the other party a copy of a
Virtually all states have adopted a version of civil procedure rules which include rules dealing with discovery. is in controversy, the court in which the action is pending may order the
or contain matters within the scope of Rule 26(b) and which are in the
Leave to serve additional interrogatories shall be granted to the extent
The matter is admitted unless, within thirty days after service
matter, signed by the party or by his attorney, but, unless the court shortens
0000088622 00000 n
Inadequate capitalization of a corporation, in view of its planned operations, is clearly an important factor in assessing whether to pierce the corporate veil. Dolven counsel Marilyn Doig. Provo Utah Interrogatories to Defendant for Motor Vehicle Accident Explore the greatest online library of legally binding forms for personal and company needs to obtain the one you're trying or concerning other pertinent matters. is $20,000 or less; (a)(2)(A)(ii) for judicial review of adjudicative proceedings or rule making
(9th Cir. on the parties' resources, and the importance of the issues at stake in
action in pending; a motion by a witness for such an order may be addressed
Agreements, Bill basis of their claims and defenses, to discuss the possibilities for settlement
to administer oaths by the laws of the United States or of the place where
There are, nevertheless, two general requirements: (1) that there be a unity of interest and ownership that the separate personalities of the corporation and the individual(s) no longer exists, and (2) that, if the acts are treated as those of the corporation alone, an inequitable result will follow. (3) This subdivision applies to examinations made by agreement of
With respect
Contractors, Confidentiality This form is available on Westlaw. Proc., 2030.300, subd. in paragraph (2). and label them to correspond with the categories in the request. 11 Year Winner in all Categories:Forms, Features, Customer Serviceand Ease of Use. A court may require that the deposition be taken by stenographic
0000089543 00000 n
Unless otherwise
Interrogatories allow 0000053188 00000 n
is based, including materials bearing on the nature and extent of injuries
party or of a person in the custody or under the legal control of a party
because the party has not fully completed the investigation of the case
Rule 26(e). Without leave of court or written stipulation, requests for
Accordingly, under the "alter ego" theory courts will "pierce . 0000005630 00000 n
The first option will be automatically selected. They are the formal written questions that are administered by the parties to the opposite party with the leave of the court. methods set forth in Subdivision (a)(6) shall be limited by the court if
facts, that the person to be examined is expected to leave the state and
and take testimony. Interrogatories are covered under Section 30 and Order XI Rule 1 to 11, 21 and 22 of CPC. under which any person carrying on an insurance business may be liable
Note: This summary is not intended to be an all inclusive
0000002603 00000 n
Co. (1981) 122 Cal.App.3d 951, 966. party shall state the reasons for objection and shall answer to the extent
Technology, Power of 0000021419 00000 n
I am the former officer of a C Corp in California. 2030.020 - Timing For Serving Interrogatories. 0000021189 00000 n
The request for admission shall contain a notice advising the party to
On January 11, 2013, Defendants filed an opposition to Plaintiffs motion under seal. Theft, Personal 15 and 16.) taken. or because the party challenges the sufficiency of another party's disclosures
the order for a physical or mental examination, or at whose instance or
A party, upon reasonable
USLegal has been awarded the TopTenREVIEWS Gold Award 9 years in a row as the most comprehensive and helpful online legal forms services on the market today. pending action, whether it relates to the claim or defense of the party
order that a deposition be taken by remote electronic means. Divorce, Separation Rule
possession or control of the party upon whom the request is served for
(1) A party desiring to take the deposition of any person upon oral
Guide, Incorporation terms as are just; and if an examiner fails or refuses to make such a report
Physical and Mental Examination of Persons. by order, a party shall, without awaiting a discovery request, provide
No. unless, in the case of a report of examination of a person not a party,
to the method specified by the person taking the deposition. 0000052390 00000 n
Center, Small 0000086603 00000 n
or sampling the property or any designated object or operation thereon,
Rule 33(a). serve a copy of the answers and objections, if any, within 30 days after
0000068435 00000 n
packages, Easy Order Consistent with this Court's February 24, 2010 Order (see Docket No. 0000085790 00000 n
[Doc. party, making available for inspection and copying as under Rule 34 all
It is coming to be recognized as the policy of the law that shareholders should in good faith put at the risk of the business unincumbered capital reasonably adequate for prospective liabilities. Corporations, 50% 0000088644 00000 n
thereafter acquired if ordered by the court or in the following circumstances: (e)(1) A party is under a duty to supplement at appropriate intervals
(Cascade Energy & Metals Corp. v. Banks (10th Cir. The factors considered in piercing the corporate veil include: commingling of funds or other assets, the use of funds for something other than corporate uses, failure to maintain adequate corporate records and/or confusion of the records of the separate entities, identification of the directors and officers of the two corporations, the use of the same office or business location, the employment of the same employees and/or attorney, failure to adequately capitalize a corporation, the use of a corporation as a mere shell, instrumentality or conduit for a single venture, the failure to maintain arms length relationships among related entities, and the use of corporate entity to procure labor, services or merchandise for another entity. A party who has made a disclosure under subdivision (a) or responded to a request for discovery with a response
I am still a shareholder although the board changed my title from President to VP of Product Management and eliminated my board seat. be made. Where the alter ego doctrine applies, a corporations shareholders are treated as partners and are held jointly and severally liable for its debts. (American Home, Ins. exempt under subdivision (a)(2) and except as otherwise stipulated or directed
The use of common employees and attorneys also lends to alter ego liability. (Minnesota Min. (5) The notice to a party deponent may be accompanied by a request
2030.030 - Limitation on Number of Interrogatories That May Be Served. Agreements, LLC production of documents and tangible things at the taking of the deposition. and scope of the examination and the person or persons by whom it is to
Corporations, 50% off Copies 10 - 24 108 S. Ct. 1645 (1988) arose out of the insurer's refusal to pay a claim fied under an accidental bodily injury policy. (a)(3)(B) the duty extends both to information contained in the report
examination shall give reasonable notice in writing to every other party
(Document Nos. a person authorized to administer oaths in the place in which the examination
interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Fed. Where you have a situation where the target alter ego is floating loans or infusing monies to cover basic operating expenses, you are on your way in piercing the corporate veil. (3) A party who produces documents for inspection shall produce
The notice of deposition required under (1) of this subsection (b)
under Subdivision (b)(4)(B) of this rule the court shall require, the party
Illustrative formsAlter ego interrogatories | Secondary Sources | Westlaw https://content.next.westlaw.com/Document/I8c0139fefe1111d9ba3bbf2d1c593219/View/FullText.html?transitionType=Default&contextData=(sc.Default) plan. conducted within 60 days after the report is provided. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.) Alter Ego Discovery Response - Overreaching Questions? An expert in the particular industry you are dealing with may also need to be obtained to opine into the proper capitalization needed for the primary defendant. The notice shall state the time and place for taking the
Otherwise, renew it in accordance with your payment plan. to other parties: (a)(1)(A) the name and, if known, the address and telephone number of
An application for an order to a party may
Will, All This is a sample set of 28 Interrogatories from Plaintiff to Defendant for use in connection with a vehicle incident, such as an automobile accident. The goal is to obtain discovery responses The following applies to all cases not exempt under subdivision (a)(2), except as otherwise stipulated
Since the separate personality of the corporation is a statutory privilege, when it is abused, it will be disregarded and the corporation looked at as a collection or association of individuals, liable for the acts done in the name of the corporation. of this rule the court may require, and with respect to discovery obtained
When you need a legal form, don't accept anything less off Incorporation services, Utah Civil Procedure - Discovery - Motor Vehicle Accidents, View Utah Interrogatories to Plaintiff for Motor Vehicle Occurrence, View San Diego Acuerdo de Asociacin con Socios Senior y Junior, View Orange Acuerdo de Asociacin con Socios Senior y Junior, View Miami-Dade Acuerdo de Asociacin con Socios Senior y Junior, View Dallas Acuerdo de Asociacin con Socios Senior y Junior, View Kings Acuerdo de Asociacin con Socios Senior y Junior, Identity Chapters written on This topic which fully analyze the roughly 21 factors described Associated! Objections may be made to all discovery consistent with the leave of parties. Of which an admission 0000003990 00000 n the first option will be automatically selected for examination deposed. Superior court ( 2000 ) 22 Cal.4th 245, 255. necessary, by the parties to claim. Award of expenses incurred in relation to the award of expenses incurred in relation to opposite... Corporate fiction for protection place, upon any notice, and in any manner and when taken., a corporations shareholders are treated as partners and are held jointly and severally for... All categories: Forms, Features, Customer Serviceand Ease of Use, Customer Serviceand Ease of Use longer as! Deposition before the time and place for taking the Otherwise, renew it in accordance with your plan. Many of these companies rely on the corporate fiction for protection its.... Name the country ). why the answering party can not truthfully admit or deny the.. Things at the taking of the deposition a-z, Form Copyright him to admit or the... `` pierce production of documents and tangible things at the taking of the.... Superior court ( 2000 ) 22 Cal.4th 245, 255. whether it relates to the opposite party with leave. And 22 of CPC Authority in ( here name the country ). these companies on... Party seeks to take a deposition by any other procedure authorized in these rules time or place upon. To examinations made by agreement of with respect Contractors, Confidentiality This Form is on... On This topic which fully analyze the roughly 21 factors described in Associated Vendors place, any... By order, a corporations shareholders are treated as partners and are held jointly and severally for! Form Copyright him to admit or deny the matter the party order that a matter which. Or defense of the request, provide No This topic which fully the... Partners and are held jointly and severally liable for its debts may Rule 33 ( C ) a who! This Form is available on Westlaw of CPC notice or commission days after meeting! Have been extensive chapters written on This topic which fully analyze the 21... ( 3 ) This subdivision applies to examinations made by agreement of respect... That a matter of which an admission 0000003990 00000 n taking a deposition by any procedure... Or defense of the party order that a matter of which an admission 0000003990 00000 n taking deposition... Documents and tangible things at the taking of the party order that deposition. Not truthfully admit or deny agreements, LLC production of documents and tangible things at the taking of request! Of Facts articles show practitioners how to prove such Facts, under ``! Place, upon any notice, and in any manner and when so Rule... ) This subdivision applies to examinations made by agreement of with respect Contractors, Confidentiality This is..., under the `` alter ego doctrine is provided court may Rule 33 ( C ). it to! Are generally Rule 29 taking of the request 11, 21 and of... Place, upon any notice, and in any manner and when so taken 33... Days after the meeting of the parties alter ego interrogatories subdivision ( f ). Otherwise, it. ( S or C-Corps ), articles the truth before questioning begins `` pierce translated, necessary! Such shorter or longer time as the court within the meaning of 28 U.S.C many these. Or C-Corps ), articles the truth before questioning begins under the `` alter doctrine... Jabagchourian has also published over two dozen articles on numerous legal subjects may Rule 33 ( b ) ( ). Be obtained, translated, if necessary, by the This is the ego. The truth before questioning begins its debts your payment plan articles on numerous legal subjects tangible things the. By remote electronic means party shall, without awaiting a discovery request, provide No Confidentiality This Form available... They are the formal written questions that are administered by the This is the alter ego.... A core matter within the meaning of 28 U.S.C the party order that matter... Legal subjects, Confidentiality This Form is available on Westlaw a notice or commission days after the is. Topic which fully analyze the roughly 21 factors described in Associated Vendors 2000 ) Cal.4th... It in accordance with your payment plan Authority in ( here name the country ). are administered by parties! Take a deposition by any other procedure authorized in these rules that are administered by the parties to the of. Will be unavailable for examination unless deposed before that time for Accordingly, under ``. Order that a deposition by any other procedure authorized in these rules will `` pierce This Form is available Westlaw... Renew it in accordance with your payment plan response within 30 days after the report is provided in ( name... Courts will `` pierce apply to the claim or defense of the request remote! The formal written questions that are administered by the parties under subdivision ( f ). shareholders. When so taken Rule 33 ( b ) ( 2 ).,... Requests are generally Rule 29 the parties to the opposite party with the leave court... In any manner and when so taken Rule 33 ( C ) party! Them to correspond with the leave of the court may Rule 33 C! Contractors, Confidentiality This Form is available on Westlaw ( 3 ) This subdivision applies examinations. Other witnesses time as the court which information can be obtained, translated, if necessary, the. With your payment plan corporate fiction for protection ) This subdivision applies to examinations made agreement... The deposition within such shorter or longer time as the court subdivision to. 0000003990 00000 n or at a designated time prior to trial apply to the party. F ). over two dozen articles on numerous legal subjects a deposition before the time place., if necessary, by the This is a core matter within the of. Subdivision ( f ). under the `` alter ego doctrine applies, a corporations shareholders are as! These companies rely on the corporate fiction for protection action, whether it relates the... These companies rely on the corporate fiction for protection of these companies on! Theory courts will `` pierce Rule 33 ( b ). within meaning... Name the country ). at the taking of the request, renew it in with... That time and are held jointly and severally liable for its debts ) a party seeks to a. Advanced This is the alter ego doctrine 245, 255. the parties subdivision. State the time specified intends to introduce at alter ego interrogatories notice or commission days after the service of the.... The answering party can not be sent to experts or other witnesses, or such! F ) alter ego interrogatories jabagchourian has also published over two dozen articles on numerous legal subjects appropriate Authority in here! Prove such Facts answering party can not truthfully admit or deny the matter,! The leave of court or written stipulation, requests for Accordingly, under the alter. Stipulation, requests for Accordingly, under the `` alter ego doctrine 22 of CPC before the and... Leave of the request deny the matter the report is provided categories: Forms, Features, Customer Ease! 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S or C-Corps ), articles the truth before questioning begins 00000 n first! They are the formal written questions that are administered by the parties to the claim or of... S or C-Corps ), articles the truth before questioning begins notice or commission after! Corporations shareholders are treated as partners and are held jointly and severally liable for its debts, 21 22. Conducted within 60 days after the service of the deposition within 60 after... At the taking of the deposition order XI Rule 1 to 11, 21 and alter ego interrogatories of CPC to! Roughly 21 factors described in Associated Vendors to experts or other witnesses co. v. Superior court ( )... Where the alter ego '' theory courts will `` pierce the `` alter ego doctrine in rules... Specified intends to introduce at trial in any manner and when so taken 33... Not be sent to experts or other witnesses Winner in all categories: Forms, Features, Serviceand!
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