Deceit and Fraudulent Misrepresentation in Transmission of Sexual Disease.
As used in these interrogatories, the words "occurrence" or "alleged occurrence" shall mean the facts involved in the combined events and incidents which allegedly caused injury or damage to the plaintiff as a result of deceit and fraudulent misrepresentation in the transmission of a sexual disease from the defendant to the plaintiff.
1. Please identify yourself fully, giving your full name, age, residence, business address, and occupation, and if married, give the name of your spouse.
2. Please identify and describe the appearance of each and every person who observed or was present in the vicinity of the plaintiff's alleged occurrence, giving the name and address of each such person, if known to you.
3. Please describe fully each and every source of knowledge about the alleged occurrence of which you are aware, including: