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PRETRIAL INTERROGATORIES TO INDIVIDUAL DEFENDANT 1 . Please state your full name, as well as all other names you have ever used. ANSWER: ________________________________________ ________________________________________ ________________________________________ 2 . Please state your Minnesota Drivers License number and Social Security number. ANSWER: ________________________________________ ________________________________________ ________________________________________ a. If married, please state your spouse's name, Minnesota Drivers License number and Social Security number. ANSWER: ________________________________________ ________________________________________ ________________________________________ 3 . Were the items, services, sums of money, rented equipment, or other matters described in the exhibits to each of Plaintiff's Petitions (if more than one) in this lawsuit received or used by Defendant or its agents, employees or representatives? ANSWER: ________________________________________ ________________________________________ ________________________________________ If your answer to Interrogatory No. 3 is negative, then itemize specifically anything that you claim was not received, used, rented, or otherwise accepted. In this answer, identify by invoice number or other document number or by a complete description each item you dispute: ANSWER: ________________________________________ ________________________________________ ________________________________________ 4 . Did Defendant or its agents receive the invoices or other memoranda made exhibits to each of Plaintiff's Petitions (if more than one) on file herein. Answer yes or no. ANSWER: ________________________________________ ________________________________________ ________________________________________ - 1 - 5 . If you have denied receiving any of the invoices or other documents made exhibits to any of Plaintiff's Petitions on file herein, please specify precisely which documents you claim Defendant did not receive. ANSWER: ________________________________________ ________________________________________ ________________________________________ 6 . Was any objection ever made as to the form or content of exhibits to any of Plaintiff's Petitions on file herein? ANSWER: ________________________________________ ________________________________________ ________________________________________ If so, please state: a. The date of each such objection. ANSWER: ________________________________________ ________________________________________ ________________________________________ b. Who made each such objection? A NSWER: ________________________________________ ________________________________________ ________________________________________ c. To whom each such objection was made. ANSWER: ________________________________________ ________________________________________ ________________________________________ d. As to each oral objection, state the verbatim content thereof. ANSWER: ________________________________________ ________________________________________ ________________________________________ e. As to each written objection, state the verbatim content and form thereof or attach hereto a true and correct copy thereof. ANSWER: ________________________________________ ________________________________________ ________________________________________ - 2 - 7 . Are the prices or other charges or amounts of money which Plaintiff is seeking in this lawsuit that are indicated on the exhibits to any of Plaintiff's Petitions reasonable? ANSWER: ________________________________________ ________________________________________ ________________________________________ a. If you deny the reasonableness of any of the prices or other charges or other sums of money, please specify that part which you dispute, stating the reason or reasons for the dispute, and what you claim should be the reasonable price. ANSWER: ________________________________________ ________________________________________ ________________________________________ 8 . Was any payment made to Plaintiff on the claim asserted in this lawsuit for the items or services or other charges or sums of money listed on the exhibits to any of Plaintiff's Petitions in this suit for which credit has not already been given? If so, please specify each such alleged payment by date and amount. ANSWER: ________________________________________ ________________________________________ ________________________________________ 9 . Do you claim any offset to Plaintiff's claim in this suit for which no credit has been given by Plaintiff? ANSWER: ________________________________________ ________________________________________ ________________________________________ a. If so, please state the nature, reason and amount for each such offset. ANSWER: ________________________________________ ________________________________________ ________________________________________ 10 . Please state whether Plaintiff or its agents made written demand on Defendant for the payment of the items or services or other charges or sums of money listed on the exhibits to all of Plaintiff's Petitions more than thirty (30) days prior to the date of these Interrogatories. ANSWER: ________________________________________ ________________________________________ ________________________________________ - 3 - 11 . Do you acknowledge that Plaintiff should recover the sum of money it has requested in this lawsuit? ANSWER: ________________________________________ ________________________________________ ________________________________________ 12 . If you acknowledge that Plaintiff should recover part of the sum of money it is requesting in this lawsuit, then state that amount of money that you acknowledge is due Plaintiff. ANSWER: ________________________________________ ________________________________________ ________________________________________ 13 . If you contend that you received no benefit from Plaintiff regarding the debt made the basis of Plaintiff's lawsuit, then state specifically all of the facts that you claim support such a contention. ANSWER: ________________________________________ ________________________________________ ________________________________________ 14 . Do you contend you should not be liable for the transaction made the basis of this lawsuit? ANSWER: ________________________________________ ________________________________________ ________________________________________ a. If you contend that any other individual or corporation should be liable, then state: 1. The name and address of any individual you claim should be liable, or, the correct corporate name of any corporation you claim should be liable. ANSWER: ________________________________________ ________________________________________ ________________________________________ 2. The name of the officer or director of any such corporation who consented and approved to the transaction made the basis of this lawsuit. ANSWER: ________________________________________ ________________________________________ ________________________________________ - 4 - b. If there was a previous business from which any such corporation was formed, then please state: 1. The name and owner of the previous business. ANSWER: ________________________________________ ________________________________________ ________________________________________ c. Do you contend that Plaintiff was ever notified that Plaintiff was dealing with this other party? ANSWER: ________________________________________ ________________________________________ ________________________________________ If so, state: 1. The date, form and content of each such notice: ANSWER: ________________________________________ ________________________________________ ________________________________________ 15 . State all the facts (not previously stated herein) that you are aware of that tend to show Plaintiff should not recover its alleged debt from you or any other person or entity (identifying by name and address each source of information) as well as all facts necessary to make complete or make not misleading your answers to the foregoing written interrogatories. ANSWER: ________________________________________ ________________________________________ ________________________________________ 16 . Identify the names and addresses of all persons with knowledge of the facts made the basis of this lawsuit. ANSWER: ________________________________________ ________________________________________ ________________________________________ - 5 -

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