Special Interrogatories – Set One

Identify each item of work of HCI Systems, Incorporated for the project that was deficient as alleged in your cross‑complaint.For each item of work identified in Interrogatory Number 1, state every date on which you gave notice of the deficiency to HCI Systems, Incorporated.For each notice date identified in Interrogatory Number 2, describe the manner and method in which you gave notice of the deficiency to HCI Systems, Incorporated.For each item of work identified in Interrogatory Number 1, identify every person with knowledge, including name, title, employer, telephone number, electronic‑mail address, and physical address.For each item of work identified in Interrogatory Number 1, state the amount you paid to repair that item.For each item of work identified in Interrogatory Number 1 that has not yet been repaired, state the estimated cost of repair.List all damages to the project caused by HCI Systems, Incorporated as alleged in your cross‑complaint.For each damage identified in Interrogatory Number 7, state every date on which you gave notice of the damage to HCI Systems, Incorporated.For each notice date identified in Interrogatory Number 8, describe the manner and method in which you gave notice of the damage.For each damage identified in Interrogatory Number 7, identify every person with knowledge, including name, title, employer, telephone number, electronic‑mail address, and physical address.For each damage identified in Interrogatory Number 7, state the amount you paid to repair that damage.For each damage identified in Interrogatory Number 7 that has not yet been repaired, state the estimated cost of repair.For each damage identified in Interrogatory Number 7, describe every request you made to HCI Systems, Incorporated to correct the damage.Identify every scope of work that HCI Systems, Incorporated performed in a substandard manner, as alleged in your cross‑complaint.State the basis for all lost profits you incurred as a result of being unable to use the building due to the acts or omissions of HCI Systems, Incorporated.Identify each individual who performed repairs related to the deficient work of HCI Systems, Incorporated.Identify each individual you are aware of who possesses knowledge of any fact supporting the allegations in your cross‑complaint.

HCI Systems, Inc. v. Global Brands Jam, Inc., et al.

Special Interrogatories – Set One

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