1. What is the name and address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed?
2. List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. (Please include in this list, the name(s), address, phone number, and job title of the Defendant’s employee who picked up the rat and took it away after it attacked Galen Haldeman, and please state whether that person is still employed by the Defendant.)
3. Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance of each statement.
4. State the name and address of every person known to you, your agents, or your attorneys who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared.
5. (a) Please list the names, addresses, and telephone numbers of everyone (including employees) who has complained or simply claimed he or she saw a rat or other rodent on Walt Disney World Orlando property from April 4, 2009, to December 31, 2014. For each person listed, please list the date when the sighting is alleged to have occurred, and the place where it is alleged to have occurred, and please list the type of animal that was seen. Please describe the action Disney took in response to each of the claims.
6. (a) Please list the names, addresses, and telephone numbers of everyone who has claimed he or she was attacked by an animal on the property of Walt Disney World in Orlando from April 4, 2009, to December 31, 2014. For each person listed, please list the date when the attack is alleged to have occurred, and the place where it is alleged to have occurred, and please list the type of animal that was involved, and please describe the injuries that the victims alleged they suffered in the attacks. Please also provide the case names and court case numbers for all cases that resulted in lawsuits. (b) Please describe the action Disney took in response to each of the attacks listed.
7. Describe in detail all studies or investigations the Defendant has undertaken or directed others to undertake, from April 4, 2009, to April 4, 2015, concerning rats and other rodents in the Defendant’s Orlando park. Please provide the dates of each investigation and please describe the conclusions of each investigation, and please describe all steps the Defendant took in response to each investigation. Please provide the names, address, and telephone numbers of the persons or entities that performed the studies or investigations.
8. Please describe in detail the Defendant’s programs and procedures in place from April 4, 2009, to December 31, 2014, for dealing with rats in the Defendant’s Orlando park.
9. Please provide individuals’ and companies’ names, addresses, and telephone numbers of all persons and companies that have performed any work on the Defendant’s Orlando resort property from April 4, 2009 to December 31, 2014, pertaining to rodent control or eradication. (This question includes the Defendant’s employees as well as nonemployees.) For each individual and company named, please describe when the company performed work at the property, and please describe the nature of the work that was performed.
10. Please provide individuals’ and companies’ names, addresses, and telephone numbers of all persons and companies that have bidded or otherwise applied to perform any work on the Defendant’s Orlando resort property from April 4, 2009 to December 31, 2014, pertaining to rodent control or eradication, or who have sought to perform any work on the Defendant’s Orlando resort property from April 4, 2009 to December 31, 2014, pertaining to rodent control or eradication. For each individual and company listed, please describe when the company bidded or applied for work or otherwise sought work, and for each individual and company listed please state whether the individual or company was hired and, if not, why not.
11. Please list the dates for each time between April 4, 2009, and April 30, 2014, that the Defendant’s Orlando resort property was cited or warned or otherwise advised by any governmental authority that there was a problem with rats or other rodents on the Defendant’s Orlando property, or that the Defendant needed to do something about rats or other rodents on its property. For each date provided, please describe the nature of the citation or communication, and please list the name of the entity that gave the citation, warning, or notice, and please provide the case number and other identifying information for each such event, and please describe the corrective action the Defendant took to correct the situation that gave rise to the citation or warning or notice.
12. Please list the dates for each time between April 4, 2009, and April 30, 2014, that the Defendant’s Orlando resort property was cited or warned or otherwise advised by any governmental authority that there was a problem with garbage or trash or other refuse on the Defendant’s Orlando property, or that the Defendant needed to do something about garbage or trash or other refuse on its property. For each date provided, please describe the nature of the citation or communication, and please list the name of the entity that gave the citation, warning, or notice, and please provide the case number and other identifying information for each such event, and please describe the corrective action the Defendant took to correct the situation that gave rise to the citation or warning or notice.
13. What does the Defendant believe to be the cause of rats and other rodents living on its property? Where does the Defendant think the rats come from, and why do they come onto the Defendant’s property?
14. What did the Defendant do with the rat that attacked Galen Haldeman? If the Defendant failed to have the rat examined for disease, please explain why the Defendant failed to get the rat tested. Provide the name, address, telephone number, and job title of the Defendant’s employee who told the Haldemans that they would have the rat tested for disease, and please state whether that person(s) is still employed by the Defendant.