Request for Production

IN THE SECOND JUDICIAL DISTRICT COURT OF BUTTE, SILVER BOW, CITY/COUNTY, STATE OF MONTANA

BEFORE THE HONORABLE JUDGE KRUEGER, DISTRICT COURT JUDGE

* * * * * * *

MARY SMITH,__________________ )

)

Plaintiff(s) ) REQUEST FOR

) INTERROGATORIES

v. )

) Case No. CVP-0097

OWEN JONES AND DOLLY JONES, DBA )

O & D FAMILY CAMPGROUND )

Defendant(s) )

* * * * * * *

PLAINTIFF’S FIRST REQUEST FOR PRODUCTION

____________________________________________________________

_________________

Plaintiff, Mary Smith, requests that Defendant O&D Family Campground, Owen and Dolly Jones, owners, produce the following documents in connection with this matter. If objection is made, please state the reason for the objection. If denying the matter, please set forth, in detail the reasons why the answering party cannot produce such documentation.

1. Please state the full business name of the campground as well as the legal description of the property where the accident occurred.

2. Please provide the names, address and phone numbers of all owners, partners or investors of the above named campground.

3. Please identify all expert witnesses the defense plans on calling to testify and provide credentials for each to support why they are considered experts in the area that they are testifying.

4. Please provide copies of all insurance...