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Help rewording my interrogatories. INTERROGATORIES: State the legal name for the establishment where the accident happened, the address, employees name who were working during the

Help rewording my interrogatories.

INTERROGATORIES:

  1. State the legal name for the establishment where the accident happened, the address, employees name who were working during the accident, and the owner of the company.
  2. What are the safety regulations at Stamper' Oil Rig, Inc.?
  3. Did you take any precaution on the day of the accident? If so, what were the

precautions?

  1. Were employees notified of the accident that occurred? If so, state the employees names and job titles.
  2. Did anyone other than Mr. Shealy visit the oil rig on December 19th of 2019?
  3. Did you make the statement, "I am so sorry! This is exactly why our safety standards tell us not to leave the wrenches on pipes"? If so, were you not concerned with the injuries sustained by Mr. Shealy?
  4. Did you make the statement to a customer saying, "I would never buy gym equipment from a man who doesn't even know how to use it"? If so, did you purposely say this to derail the business of Mr. Shealy? Also state the name and direct contact of that customer.
  5. Do you take responsibility for the accident that took place at your oil rig?
  6. Did anyone witness the accident that took place at your oil rig on December 19, 2019?
  7. State the names and addresses of the safety director at Stamper's Oil Rig, Inc., federal safety regulation compliance officer, dispatcher, on December 19, 2019.

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