> ⚠️ **DRAFT — FOR FOX ROTHSCHILD REVIEW ONLY. DO NOT SERVE AS-IS.** > This is a starting template prepared for the client. Counsel must (1) confirm/replace every bracketed item, (2) tailor objections to Panda's *actual* Set One responses, (3) insert real supplemental content, (4) obtain the client's verification under oath, and (5) serve. Interrogatory responses are due **~30 days from 7/30/2026 service (≈ early Sept. 2026; email service adds ~2 court days)**. Verified responses required (CCP §2030.250). --- JACK I. SIEGAL (SBN [___]) jsiegal@foxrothschild.com T.M. BROWN (SBN [___]) FOX ROTHSCHILD LLP 345 California Street, Suite 2200 San Francisco, CA 94014 T: 415.364.5540 F: 415.391.4436 Attorneys for Plaintiff PANDA SOLUTIONS, LLC ## SUPERIOR COURT OF THE STATE OF CALIFORNIA ## COUNTY OF MONTEREY --- **PANDA SOLUTIONS, LLC,** a Washington limited liability company, Plaintiff, v. **PRO MECHANICAL SERVICES INC.,** a Washington corporation; RSP HOLDINGS, INC., a California corporation; ALCAZAR HEATING AND AIR CONDITIONING, LLC, a California limited liability company; and DOES 1 through 20, inclusive, Defendants. Case No.: **25CV001352** **PLAINTIFF PANDA SOLUTIONS, LLC'S RESPONSES TO DEFENDANT PRO MECHANICAL SERVICES, INC.'S SUPPLEMENTAL INTERROGATORIES** Assigned for all purposes to Hon. Carrie M. Panetta, Dept. 14 Action Filed: March 12, 2025 Trial Date: September 28, 2026 --- **PROPOUNDING PARTY:** Defendant PRO MECHANICAL SERVICES, INC. **RESPONDING PARTY:** Plaintiff PANDA SOLUTIONS, LLC **SET NUMBER:** Supplemental Plaintiff PANDA SOLUTIONS, LLC ("Plaintiff") responds to the Supplemental Interrogatories of Defendant PRO MECHANICAL SERVICES, INC. ("Defendant") as follows: ### PRELIMINARY STATEMENT These responses are made solely for purposes of this action. Discovery, investigation, and trial preparation are ongoing and continuing. These responses are based on information and documents reasonably available to Plaintiff as of this date. Plaintiff has not completed its investigation, discovery, or trial preparation, including retention and analysis by its expert(s). Plaintiff reserves the right to amend, supplement, correct, or clarify these responses as additional information becomes available, and to introduce at trial any information, documents, or evidence later discovered. No incidental or implied admission is intended, and the fact that Plaintiff has responded to or objected to any interrogatory shall not be deemed an admission that Plaintiff accepts any factual or legal premise contained therein. ### GENERAL OBJECTIONS The following objections are incorporated by reference into each response below as though fully set forth: 1. Plaintiff objects to each interrogatory to the extent it seeks information protected by the attorney-client privilege, the attorney work-product doctrine (CCP §§ 2018.010–2018.030), or any other applicable privilege or protection. No privileged information is intentionally provided; any inadvertent disclosure is not a waiver. 2. Plaintiff objects to the extent any interrogatory seeks information constituting or relating to expert opinion or the substance of expert testimony, on the ground that such discovery is premature and governed by the expert-disclosure procedures of CCP § 2034.010 et seq. Plaintiff will disclose expert information at the time and in the manner required by statute and any applicable court order. 3. Plaintiff objects to each interrogatory to the extent it is vague, ambiguous, overbroad, unduly burdensome, oppressive, or not reasonably calculated to lead to the discovery of admissible evidence. 4. Plaintiff objects to the extent any interrogatory seeks information equally available to Defendant, already in Defendant's possession, or obtainable from public records or from other parties. 5. Plaintiff objects to the extent any interrogatory seeks information outside Plaintiff's possession, custody, or control. 6. Plaintiff objects to the extent any interrogatory exceeds the permissible scope or number of supplemental interrogatories under CCP § 2030.070. Subject to and without waiving the foregoing, Plaintiff responds: ### RESPONSE TO SUPPLEMENTAL INTERROGATORY NO. 1 Plaintiff incorporates the Preliminary Statement and General Objections. Plaintiff further objects that the interrogatory is compound and, to the extent it purports to require Plaintiff to re-verify every prior response, is overbroad and unduly burdensome. Subject to and without waiving the foregoing objections, Plaintiff responds as follows: > **[COUNSEL — SELECT / EDIT ONE:]** > > **(a) If prior responses remain accurate:** Having reviewed its prior responses to Defendant's Form Interrogatories and Specially Prepared Interrogatories, Set One, Plaintiff's prior responses remain correct and complete as of the date of this response, except as Plaintiff's investigation and expert analysis are ongoing and Plaintiff reserves the right to supplement. > > **(b) If there are updates (likely re: damages):** Having reviewed its prior responses, Plaintiff supplements as follows: [Identify each prior response by number and state the corrected/completed information — e.g., updated crop-loss damages calculation per Plaintiff's damages expert; additional facts learned in discovery; updated witness/contact information]. Plaintiff's prior responses are otherwise correct and complete, subject to ongoing investigation and expert analysis. --- ### VERIFICATION I, [NAME], am a [title, e.g., Manager/Member] of Plaintiff PANDA SOLUTIONS, LLC, and am authorized to make this verification on its behalf. I have read the foregoing **RESPONSES TO DEFENDANT PRO MECHANICAL SERVICES, INC.'S SUPPLEMENTAL INTERROGATORIES** and know their contents. The matters stated therein are true of my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on __________, 2026, at __________, [State]. _______________________________ [NAME], for PANDA SOLUTIONS, LLC --- *As to objections:* Dated: __________, 2026 FOX ROTHSCHILD LLP By: _______________________________ Jack I. Siegal Attorneys for Plaintiff PANDA SOLUTIONS, LLC *(Proof of service to be attached per the firm's standard form and the parties' e-service agreement, CCP § 1010.6.)*