State Court of Fulton County

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File & ServeXpress
Transaction ID: 64620355
IN THE STATE COURT OF FULTON COUNTY Date: Jan 14 2020 04:51PM
STATE OF GEORGIA LeNora Ponzo, Chief Clerk
Civil Division

MICHELLE LAMB,
Plaintiff,

CIVIL ACTION
vs. FILE NO.:

JURY TRIAL DEMANDED

LYFT, INC. and COREY HASSAN GRIMES

Defendants.

PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT LYFT, INC.

COMES NOW, Michelle Lamb, Plaintiff, in the above-styled civil action, by and

through her undersigned counsel, hereby serve on Defendant Lyft, Inc. the following

Interrogatories, pursuant to O.C.G.A. § 9-11-33 and request that same be answered under oath,

within forty-five (45) days from the date of service, as provided by law, with a copy of such

answers furnished to the attorney for said Plaintiff, Lashonda Council Rogers, Esq., Council &

Associates, 50 Hurt Plaza, SE, Suite 650, Atlanta, Georgia 30303.

Information sought in these Interrogatories shall be information known to you, your

attorneys, agents, representatives, investigators, or other persons having information regarding

the incident complained of. If answers are based on information supplied to you, please indicate

that the answer is not based on personal knowledge and provide the name and address of the

person providing the information.

For purposes of clarity, the following definitions will be used in reference to answering

said Interrogatories.
 DEFINITIONS

1. When used in these Interrogatories, the terms “you” and “your,” or any synonym

thereof is intended to, and shall embrace and include, Lyft, Inc., each of your attorneys, agents,

servants, employees, representatives, private investigators and others who are in possession of, or

who may have obtained information for or on your behalf.

2. The term “document” shall mean and include any document or thing including,

but not limited to, any writings, contracts, agreements, notes, letters, microfilms, drawings,

graphs, photographs, tape recordings, e-mails or other electronically recorded sounds or

materials.

3. “Identify” or “identity,” when used in reference to a document, means to provide

the date, identity of author or addressee, type of document (e.g., letter, memorandum, telegram,

chart, etc.) necessary to enable the custodian to locate a particular document and a summary of

pertinent content.

4. “Identify” or “identity,” when used in reference to an individual person, means to

state his or her full name and present or last known address, the present or last known position

and business affiliation of such person and his or her position and business affiliation at the time

in question.

5. The term “person” shall mean and include, in singular or plural, any person,

partnership, corporation, association or other legal entity.

Objections based on Privilege - In the event that any information, documents, or things

requested herein is withheld under a claim of privilege, please provide the following information

with respect to each:

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 1. The type of information, document, or thing, its general subject matter, the place,

and the appropriate date it was gathered, learned, prepared, or created;

2. The name, address, phone number, and title of each person who prepared, created,

learned, or gathered the information, document, or thing and the name, address, phone number,

and title of each person who has received or examined the information, document, or thing or

copy thereof; and

3. A statement of the circumstances which bear on whether or not the claim of

privilege is appropriate and whether the privilege that is claimed should extend to all or to just a

part of the information, document, or thing.

INTERROGATORIES

1.

With regard to each request for admission served upon you by the Plaintiff which you do

not fully admit, without reservation or qualification, please state for each such request:

(a) Every fact which you contend supports your denial, partial denial, or qualified

admission;

(b) The identity of every person or entity who you contend has knowledge of the facts

upon which the denial, partial denial or qualified admission is based, giving a

summary of the information he, she or it has; and,

(c) The identity of every document or tangible item which you contend supports or

pertains to your denial, partial denial, or qualified admission.

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 2.

Does any primary insurance agreement exist under the terms of which the person or

company issuing the same may be called upon to satisfy all or part of any judgment against you

which may be entered in favor of the Plaintiff in this action?

(a) If such an insurance agreement does exist, what are the limits of liability

contained in the terms of any such agreement?

(b) If such an insurance agreement does exist, what are the legal names of each and

every party to the agreement itself and to any further or subordinate agreement

which in any way relates to the terms of any such agreement?

3.

Does any excess insurance agreement exist under the terms of which the person or

company issuing the same may be called upon to satisfy all or part of any judgment against you

which may be entered in favor of any Plaintiff in this action?

(a) If such an insurance agreement does exist, what are the limits of liability

contained in the terms of any such agreement?

(b) If such an insurance agreement does exist, what are the legal names of each and

every party to the agreement itself and to any further or subordinate agreement

which in any way relates to the terms of any such agreement?

4.

If you contend that the Plaintiff has brought this action against the wrong entity due to a

misnomer or for any other reason, please state the complete name of the correct defendant for

this action and why this is the wrong entity, and further state whether you will accept service of

an amended Summons and Complaint reflecting the information furnished by you in response to

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this Interrogatory.

5.

For all persons known to you or your representatives who has knowledge or relevant

information pertaining to the collision giving rise to this action, please provide the following

information:

(a) their name, address, place of employment and job title;

(b) their present whereabouts; and

(c) a brief description of what information such person has.

6.

State whether you or anyone acting on your behalf obtained statements in any form from

anyone. If any statement, in any form was obtained, state with respect to each such statement:

(a) the name and address of the person(s) to whom such statement was made;

(b) the date the statement was made; and

(c) the names and addresses of all persons presently having custody of the statement.

7.

Do you, your attorneys, your insurance carriers or anyone acting on your or their behalf

have or know of any photographs, motion pictures, videotapes, drawings, diagrams, recordings

of any kind or other tangible or documentary evidence concerning any of the events and

happenings alleged in this action? If so, please identify:

(a) each tangible item’s specific subject matter;

(b) the date it was made or taken;

(c) the name and last known address of the person making or taking it;

(d) what each item purports to show, illustrate or represent; and

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 (e) the name and address of each person having custody of each item or items.

8.

State the name, address, occupational title, and present whereabouts of each person

whom you expect to call as an expert witness at the trial of this case, and with respect thereto,

state the following:

(a) the subject matter on which the expert is expected to testify;

(b) the substance of the facts and opinions to which the expert is expected to testify;

(c) a summary of the grounds for each opinion to which the expert is expected to

testify; and

(d) whether any reports or other written materials or letters have been generated by

such expert for this case.

9.

With respect to each person identified in your answer to the immediately preceding

interrogatory, please identify each document upon which such person relies, if any, to support

the opinions to which the expert is expected to testify.

10.

Only if you allege any defense to this action based on jurisdiction, venue, issuance of

process, process itself, or service of process, as to each such defense, please state:

(a) each and every fact upon which you rely in asserting such defense;

(b) a complete description of all documents which you contend supports the

assertions of the said defense;

(c) the name and address of all persons having custody and control of the documents

described in (b) above; and

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 (d) the full and complete business addresses of this Defendant.

11.

If you contend that any person, firm, or entity caused or contributed to the injuries and

damages claimed by Plaintiff, please identify by name, address, job title, and employer all such

persons, firms or entities.

12.

Identify the person or persons responding to this discovery, plus all individuals who have

provided assistance in responding to the Plaintiff’s First Continuing Interrogatories, Requests for

Admissions and Requests for Production of Documents, including each person(s) name, address

and employer.

13.

Please provide the name of the Safety Director for Lyft.

14.

Was Defendant Corey Grimes an employee of Lyft on September 29, 2018? If so, please

state the following:

(a) His inclusive dates of employment;

(b) The name of each and every individual involved in the interview and hiring

process of Corey Hassan Grimes. For each such individual please state their role

in this process, as well as the individual’s present whereabouts;

(c) Was a background check done on Corey Hassan Grimes at any time? If so, please

state the date when any such background check or investigation was performed,

the person conducting it, from what agencies information was sought, and what

information was obtained through any such check or investigation; and

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 (d) If Corey Hassan Grimes is no longer an employee of Lyft, please state her last

date of employment, as well as the circumstances surrounding the termination of

her employment, and the names of the individuals involved in the decision to

terminate Corey Hassan Grimes.

15.

State whether you or anyone acting on your behalf gave, furnished, performed, or

otherwise provided any form of driver training for Defendant Corey Hassan Grimes, including

but not limited to schools, classes or instructions, or any other visual, written or oral instructions

or directions. If your response is in the affirmative, please state the following:

(a) each form of training provided;

(b) the name of the individual providing same and their present whereabouts;

(c) the location of the training;

(d) the period of time it took to complete the training;

(e) whether Corey Hassan Grimes was given a driving test following any such

training; and

(f) identify any documents related to or comprising said training, instructions,

directions, or warnings to drivers and to Corey Hassan Grimes specifically.

16.

Please identify by name and title the custodian of Corey Hassan Grimes’s complete

personnel or employment file.

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 17.

Did Corey Hassan Grimes seek medical treatment for injuries he received in the collision

which is the subject of this litigation? If so, please describe the nature and extent of his injuries.

18.

As a result of the collision, were any inspections performed by you, or anyone acting on

your behalf, or at the request or direction of any other individual, firm, agency or entity, on the

vehicle which was being driven by Corey Hassan Grimes at the time of the collision? If your

response is in the affirmative please provide the following:

(a) the name of the individual(s) conducting each and every such inspection;

(b) the party requesting any such inspection;

(c) the date each and every such inspection was conducted;

(d) the location of each and every such inspection;

(e) the findings of any such inspection; and

(f) was a written report prepared regarding the findings of any such inspection.

19.

Please state the purpose of the trip being made by Corey Hassan Grimes at the time of the

collision described in this Complaint, including but not limited to the original starting point, the

intended destination when the collision occurred, and the route taken from Corey Hassan Grimes

last stop before said collision. Please include any and all applicable addresses in your response.

20.

If Corey Hassan Grimes was not an employee, agent or representative of Lyft at the time

of the collision described in this Complaint, please describe fully the nature of his relationship

with your company. If you contend he was employed by another individual, entity, agency or

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company at the time of the collision described in this Complaint state the complete name,

address, and telephone number of his employer.

21.

Is there a document or tangible item which was responsive to one of our requests for

production of documents that you did not produce to the Plaintiff for any reason whatsoever?

(said reasons include but are not limited to not producing a document or tangible item based on a

privilege or the attorney work product doctrine).

22.

If the answer to the immediately preceding Interrogatory is in the affirmative, please

identify each and every document or item that you did not produce and state the reason why you

did not produce it.

23.

Please state whether Lyft owned the vehicle driven by Corey Hassan Grimes at the time

of the collision and, if so, provide the circumstances which lead to Defendant Corey Hassan

Grimes of the vehicle at the time of the collision.

This 14th day of January, 2020.

Respectfully Submitted,

50 Hurt Plaza, SE, Suite 650 COUNCIL & ASSOCIATES LLC

Atlanta, GA 30303
404-526-8857 (telephone) Jamie T. Agnew_________
404-478-8423 (facsimile) Lashonda Council Rogers
lrogers@thecouncilfirm.com Georgia State Bar No. 190276
jagnew@thecouncilfirm.com Jamie T. Agnew
Georgia State Bar No. 865562
Attorneys for Plaintiff

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