IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF EAST CAROLINA

Amanda Chef, on her own behalf and as :

: CIVIL ACTION
Executor of the Estate of Chef, :
Plaintiff : No. 21-CV-0001-DDE
:
v. :
:
Drug Co., :
Defendant. :

DEFENDANT’S FIRST SET OF INTERROGATORIES

DIRECTED TO PLAINTIFF AMANDA CHEF

Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Defendant requests that Plaintiff
Amanda Chef serve written answers, under oath, to the following Interrogatories within thirty (30) days of
service.

Definitions

A. The term “Plaintiff” shall mean Amanda Chef, named as Plaintiff in this lawsuit, as
well as the Executor of the Estate of Chef, Plaintiff’s employees, agents,
representatives, and all other persons and entities acting or purporting to act on
Plaintiff’s behalf.

B. The terms “Plaintiff,” “Mrs. Chef”, “you,” “your,” “yourself,” and “yourselves”
shall mean Plaintiff, as defined above.

C. The term “Incident” shall mean the death of Mr. Chef, originating at his restaurant on
June 20, 2020 and terminating at the Neartown Community Hospital.

D. The term “Chef Lawsuit” shall mean the civil action filed by Plaintiff, Amanda Chef,
by and through her attorneys, on or about February 14, 2021 in the United States
District Court for the Western District of East Carolina and docketed at No. 21-CV-
0001-DDE.

E. The term “Document” shall mean the any recording or preservation of information of
any sort and in any manner, whether printed, written, or otherwise produced by hand;
and whether recorded, reproduced, or stored by any other mechanical or electronic
 process, method, or means. Without limiting the generality of this definition, the term
includes documents, tangible things, and electronically stored information designated
by this discovery request or otherwise responsive to this discovery request, including
writings, drawings, graphs, charts, photographs, sound recordings, images, video
recordings, and other data or data compilations, stored in any medium from which
information can be obtained either directly or, if necessary, after translation by the
responding party into a reasonably usable form.

F. The terms “relate to” or “relates to” shall mean to refer to, pertain to, report on,
regard, have respect to, shown or indicate knowledge of, mention or tend to establish or
negate a particular fact either directly or indirectly.

G. For all interrogatories the term “medical professional” shall be defined as: any
individual(s) practicing any type of healing arts or practices, whether physical,
mystical, mainstream or non-conforming to mainstream medical
practices/views/understanding, regardless of categorization (such as holistic, western
style, religious, or otherwise) of healing title or style, or the title, schooling,
certifications or lack thereof by the individual(s) providing care for any ailment
(medical or otherwise) or abnormality, whether real or otherwise.

Instructions

A. Using this form or another of Plaintiff’s choosing, Plaintiff must answer each
Interrogatory separately and fully, in writing, and under oath. Plaintiff is reminded that
nonresponsive, incomplete, or evasive answers may result in the imposition of
sanctions by the Court.

B. In answering these Interrogatories, Plaintiff shall furnish all information available to it,
including information in possession of its employees, company management or
officers, attorneys, accountants, vendors, representatives, agents, investigators, and all
persons acting or purporting to act on Plaintiff’s behalf.

C. If, after exercising the diligence the law requires to pursue all sources of responsive
information, Plaintiff is unable to answer a particular Interrogatory fully, Plaintiff must
supply responsive information to the greatest extent possible, identifying what
information it has been unable to secure, explaining why it has been unable to secure
the missing information, and setting out in detail all efforts undertaken to obtain the
requested information.

D. These Interrogatories are continuing in nature, and Plaintiff is reminded of its

obligation, imposed by Rule 26(e) of the Federal Rules of Civil Procedure, to timely
supplement any answer that the Plaintiff learns is incomplete or incorrect.
 E. If Plaintiff objects to any Interrogatory or portion of an Interrogatory on the basis that
the information sought there is encompassed by a privilege, the work-product
protection, or other immunity from discovery, supply with your answers a “privilege
log” that states:

1. The basis for that objection with specificity, and

2. Whether the objection is resulting in the actual withholding of

any information, and

3. The factual foundation upon which the objection is based,

supplied in sufficient detail as to allow the court to render a
decision on the merits of that objections.

DEFENDANT’S FIRST SET OF INTERROGATORIES

INTERROGATORY NO. 1:
Please state your name (first, middle, last, maiden), age (date of birth), place (city) of birth, full name of
decedent (first, middle, last), decedents’ age (date of birth), decedents’ city of birth, and the name (first,
middle, last, maiden if female), age (date of birth), city of birth of anyone that is involved in any way with
responding to any interrogatory (primary or subsequent questions) presented by Defendant’s attorneys and
state their relationship status (how do you know them, for how long, and why they were necessary for
responding to these interrogatories with accuracy and honesty), and what their job/position and expertise, in
relation to the Plaintiff’s business or medical dealings, or the incident that resulted in decedents’ passing.

ANSWER:

INTERROGATORY NO. 2:
Identify all medical professionals seen in the past year, whether scheduled or urgent, place of appointment or
name, date, time of visit if hospital emergency room, urgent care facility, emergency medical services, fire
department emergency medical services, or any other individual that was seen, whether by appointment or
out of need without appointment, their title, specialty, hospital/clinic/private practice they are employed or
worked at when visit occurred, any advanced degrees, training, certifications, licenses, boards completed,
additional or extended training, number of years since completion of training/schooling for specialty or field
they were working at time of visit, reason for visit, whether scheduled in advance or unscheduled, and
medical advice or assessment provided at the visit.

ANSWER:
INTERROGATORY NO. 3:
State the names, addresses, medical specialty, and any other medical professional that was seen by Decedent
the past two years prior to his death. When stating each individual medical professional list their medical
specialty, reason for visit, and list any medications administered or prescribed during each individual visit,
reason for administration/prescription, occurrence or abnormality medications were intended to address,
whether it was cause for visit, related to cause for visit, or secondary, tertiary, or otherwise related to or
separate from reason for visit to medical professional. When listing medication state length of time
prescribed(begin date to last date used), any and all side effects possibly resulting from use of the
medication, any materials received with medication (instruction pamphlet, prescribing doctors’ orders for
use, dosage, and warnings provided), who prescribed, who counseled on effects of medication, and any
resulting adverse reactions from any medications that were prescribed the past two years dating back from
the date(day, month, year)of incident involving Decedent at issue in this court proceeding. Provide copies of
records or information necessary for Defendants’ counsel to acquire the records to include location,
telephone numbers, email addresses, fax numbers, and point of contact for records retrieval for each medical
visit addressed in the first part of this interrogatory.

ANSWER:

INTERROGATORY NO. 4:
State, as accurately as possible, all medications and relevant health markers (weight, blood pressure,
cholesterol, any information from labs performed, scans completed, physical observations, and Decedents’
reason for the two visits to the medical professional, the first visit when Decedent was prescribed the
medication in question and the visit prior to being prescribed medication in question, who prescribed the
medication in question. Please list all medications Decedent was taking on the day of the visit and any that
were prescribed at the visit along with a detailed summary of why the medication(s) were prescribed and for
what medical issue they were being used to address or prevent. Provide statement from Plaintiff recalling all
observations, beliefs, or thoughts that relate to Decedents’ health or physical appearance, performance, or
any deficiencies or occurrences that were abnormal to the Decedents’ normal affect or activity.

ANSWER:

INTERROGATORY NO. 5:
State, with as much accuracy as possible, the number of shifts/hours worked daily, weekly, and monthly, by
the Decedent, for the preceding eight months prior to incident previously stated, activities performed during
“average” shift, number of employees scheduled/present assisting on each shift, number of parties served or
as accurately as possible estimate number of patrons served, any and all physical activity, not limited to
walking, cooking, or any type of physical movement performed during each shift, average temperature in
kitchen, dining room, office, and any other area Decedent would have reason to inhabit during a shift and
length of time spent (on average) in each location during a shift, and any precautionary methods or
procedures practiced or mandated for prevention of workplace injury such as heat exhaustion, overexertion,
or other ailment or occurrence that could be possible, regardless of how remote that possibility may be, in the
performance of duties at Decedents’ place of business.

ANSWER:

I AFFIRM UNDER THE PENALTIES FOR PERJURY THAT THE FOREGOING ANSWERS ARE
TRUE, CORRECT, AND COMPLETE TO THE BEST OF MY KNOWLEDGE.

Date: _______________

Name: ______________________

Title or Affiliation with

Chef Company/Estate: _________________________________________

Respectfully submitted,

Timothy Brown
Timothy Brown, Student.
Library Card No. 36894
Jason Voorhees Law Offices
100 Crystal Lake Court
Midway, East West Carolina 01010
jvoorheeslaw@gmail.com
(666) 555-5555

Dated: Feb. 30, 2021

 CERTIFICATE OF SERVICE

I, Timothy Brown, hereby certify that on October 30, 2020 I served the foregoing First Set of
Interrogatories on Plaintiff’s counsel-of-record by first-class mail, postage prepaid, addressed as follows:

Timothy Brown, Student.

287 Chestnut Drive
Midland, EC 01010

Timothy Brown
Timothy Brown, Student.

Dated: Oct. 30, 2020

HONOR CODE DECLARATION

In accordance with the Charleston School of Law Honor Code, I, Timothy Brown, hereby certify that
I meaningfully contributed to the preparation of my written discovery, received no assistance of any kind
from any other individuals, students, or otherwise, of which I now attach in this email.