Michael Thornton Esq.- #175205
WHITFIELD & Assoc.
4631 East Imperial Highway
Building B, Suite 202
Santa Fe Springs, California 90670
Telephone: (562) 406-7444
Facsimile: (562) 406-7447

Attorneys for Plaintiff

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

FOR THE COUNTY OF ORANGE

MARGARET McDONALD,				CASE NO: 91626

		Plaintiff,				PLAINTIFF’S SPECIALLY
							PREPARED INTERROGATORIES
v.							
							
TELETRAC, INC.,                

		Defendants.

PROPOUNDING PARTY	:	Plaintiff, MARGARET McDONALD

RESPONDING PARTY	:	Defendant, TELETRAC, INC.                                   	                                
SET NUMBER			:	ONE

	TO DEFENDANT TELETRAC, INC. AND THEIR ATTORNEYS OF RECORD:

REQUEST IS HEREBY MADE, pursuant to California Code of Civil Procedure §2030, that the above-referenced responding party answer fully the following specially 

prepared interrogatories under oath.
SPECIAL INTERROGATORY NO. 1:
	State the precise date that Plaintiff Margaret McDonald was hired by Defendant Teletrac, Inc.

SPECIAL INTERROGATORY NO. 2:
	State the exact title and job description given to Plaintiff Margaret McDonald at the time of her initial hiring.
SPECIAL INTERROGATORY NO. 3:
	State each and every promotion and/or salary increase given to Plaintiff Margaret McDonald from the date of her initial hiring until July 16, 1997.
SPECIAL INTERROGATORY NO. 4:
	List every employee (whether full-time or temporary) who worked in the billing department of Defendant Teletrac Inc.’s Los Angeles office on July 1, 1997.
SPECIAL INTERROGATORY NO. 5:
	List each individual as set forth in your response to the previous interrogatory, who is currently employed by Defendant Teletrac, Inc.
SPECIAL INTERROGATORY NO. 6:
	For every individual set forth in your response to the above interrogatory, please set forth their current job description and location of employment.
SPECIAL INTERROGATORY NO. 7:
	For every individual set forth in your response to interrogatory number 4 above, who is not currently employed by Defendant Teletrac, Inc., please set forth the last date said individual worked for Defendant Teletrac, Inc. and the final position held by said individual.

SPECIAL INTERROGATORY NO. 8: 
	When was the decision made by Defendant Teletrac, Inc. to remove the billing function from the Los Angeles regional office to the Corporate office in Kansas City.
SPECIAL INTERROGATORY NO. 9:
	List every employee employed in the billing department of Defendant’s Los Angeles Office on July 1, 1997 who was informed of the decision to relocate as set forth in interrogatory number 8 above.
SPECIAL INTERROGATORY NO. 10:
	For each individual listed in response to interrogatory number 9 above, please state the date and manner each individual was notified of Defendant’s intention to relocate the billing department.
SPECIAL INTERROGATORY NO. 11:
	Did Defendant Teletrac, Inc. hire any temporary employees through Premier Personnel Services to assist in relocating the billing department from Los Angeles to Kansas City?
SPECIAL INTERROGATORY NO. 12:
	Set forth the name of each individual in response to interrogatory number 11 above.
SPECIAL INTERROGATORY NO. 13: 
	For each individual set forth in response to interrogatory number 12 above, please state the last date each individual was employed by Defendant Teletrac, Inc.                         

SPECIAL INTERROGATORY NO. 14:	
	Please set forth the name of each employee of Defendant Teletrac, Inc. who was aware of Plaintiff’s disability status as of July 10, 1997.

DATED:						 WHITFIELD & Assoc.

							Michael Thornton
						     Attorney for Plaintiff