Form 203

(6) State whether it is your business practice to prepare, or to obtain from your employees, a written

report of the circumstances surrounding injuries sustained by persons on the subject premises.

(7) State whether any written report of the incident described in the Complaint was prepared by you

or your employees in the regular course of business.

(8) State whether any warning or caution signs or barriers were erected at or near the scene of the

incident at the time the Plaintiff claims to have been injured.

(9) If the answer to the previous interrogatory is in the affirmative, please state:

(a) the name, address and employer of the person who erected the warning or caution signs or barriers;

(b) the name, address and employer who instructed the person to erect the warning or caution signs

or barriers;

(c) the time and date a sign or barrier was erected;

(d) the size of the sign or barrier and wording that appeared thereon.

(10) State whether you received, at any time within twenty-four (24) months before the incident

described by the Plaintiff, complaints from anyone about the defect or condition that the Plaintiff claims

caused the Plaintiff’s injury.

(11) If the answer to the previous interrogatory is in the affirmative, please state:

(a) the name and address of the person who made the complaint;

(b) the name and address of the person to whom said complaint was made;

(c) whether the complaint was in writing;

described by the Plaintiff, complaints from anyone about the defect or condition that the Plaintiff claims

caused the Plaintiff’s injury.

(11) If the answer to the previous interrogatory is in the affirmative, please state:

(a) the name and address of the person who made the complaint;

(b) the name and address of the person to whom said complaint was made;

(c) whether the complaint was in writing;

(d) the nature of the complaint.

(12) Please identify surveillance material discoverable under Practice Book Section 13-3 (c), by

stating the name and address of any person who obtained or prepared any and all recordings, by film,

photograph, video, audio or any other digital or electronic means, of any party concerning this lawsuit

or its subject matter, including any transcript thereof which are in your possession or control or in the

possession or control of your attorney, and state the date on which each such recordings were obtained

and the person or persons of whom each such recording was made.

(13) Are you aware of any photographs or any recordings by film, video, audio or any other digital

or electronic means depicting the incident alleged in the Complaint, the scene of the incident, or any

condition or injury alleged to have been caused by the incident alleged in the Complaint? If so,

for each set of photographs or each recording taken, obtained or prepared of each such subject,

please state:

(a) the name and address of the person who took, obtained or prepared such photographs or

recording, other than an expert who will not testify at trial;

(b) the dates on which such photographs were taken or such recordings were obtained or prepared;

(c) the subject (e.g., ‘‘scene of incident,’’ etc.);