INTERROGATORIES FOR DEALER
1. When did this defendant acquire the subject vehicle?
2. While the vehicle was in the possession of the defendant was the car ever damaged, if so explain how, the amount of damage and how it was fixed, and by whom.
3. Did this defendant ever inspect the vehicle, if so when, why, and the results?
4. Describe all service performed in this car and attach all repair orders
5. List all conversation between the parties and all testimony you will use at the trial
6. List all pre delivery services and products purchased by the plaintiff, list price and documents indicating that the plaintiff agreed to purchase the product and all conversations supporting the claim that plaintiff agreed to purchase the product or service.
7. Was the plaintiff ever told that the car had not been in an accident, and of so by whom?
8. How much money was forwarded to the MFGR to have the car certified?
9. List each employee who was involved in any way with this transaction
10. Explain the certification process and attach all documents supporting same
11. List selling prices for vehicles set forth in demand for documents number 12 .
12. Who was the used car manager who inspected the plaintiff’s vehicle and where is his report?
13. When the dealership acquired the plaintiff’s car did they own a paint thickness meter and if so was it used on the plaintiff’s vehicle?
14. If not why?