26 CITIES OF BERKELEY, OAKLAND AND EAST PALO ALTO, AND THE COUNTY OF

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1 1 THE LAW OFFICES OF STEVEN A. SILVER STEVEN A. SILVER (State Bar No ) W. Morton Avenue, Suite C Porterville, California TEL: (559) FAX: (559) Attorneys for Defendant EXCEL INDUSTRIES, INC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO THE PEOPLE OF THE STATE OF CALIFORNIA, etc., et al. 12 Plaintiffs, 13 vs ARCADIA MACHINE & TOOL, INC., et al. 16 Defendants. Case No.: REQUESTS FOR ADMISSION PROPOUNDING PARTY: 19 RESPONDING PARTIES: SET NUMBER: ONE 24 Defendant EXCEL INDUSTRIES, INC. Plaintiffs PEOPLE OF THE STATE OF CALIFORNIA, JOE SERNA, JR., THE CITIES OF BERKELEY, OAKLAND and EAST PALO ALTO, and the COUNTY OF ALAMEDA 25 TO PEOPLE OF THE STATE OF CALIFORNIA, JOE SERNA, JR., THE 26 CITIES OF BERKELEY, OAKLAND AND EAST PALO ALTO, AND THE COUNTY OF 27 ALAMEDA AND TO THEIR ATTORNEYS OF RECORD: REQUESTS FOR ADMISSION, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\RFA1.PLT

2 1 Pursuant to Code of Civil Procedure, Section 2033, Defendant 2 EXCEL INDUSTRIES, INC. (hereinafter referred to as "EXCEL") 3 requests that plaintiffs PEOPLE OF THE STATE OF CALIFORNIA, JOE 4 SERNA, JR., THE CITIES OF BERKELEY, OAKLAND and EAST PALO ALTO, 5 and THE COUNTY OF ALAMEDA (hereinafter jointly referred to as 6 "PLAINTIFFS") each separately admit or deny, in writing and under 7 oath, the following requests for admission within thirty-five 8 (35) days of the date on which these requests were served I DEFINITIONS FUNCTIONING, when referring to a firearm, shall mean 13 the number of bullets that are fired each time the trigger is 14 pulled, and the speed at which bullets can be fired from the 15 firearm. 16 II. 17 REQUESTS 18 REQUEST NO Please admit that in 1993, there were 24,526 murders in the 20 United States. REQUEST NO Please admit that in 1996, there were 19,645 murders in the 23 United States. 24 REQUEST NO.3 25 Please admit that, as reported in the F.B.I.ls 1998 Uniform 26 Crime Reports (released in October, 1999), there were 16, murders in the United States in REQUESTS FOR ADMISSION I c:\legal\casefile\118-excel\2-sf\discover\rfa1.plt SET ONE

3 1 REQUEST NO.4 2 Please admit that the 1993 national murder rate in the U.S. 3 was approximately 9.5 per 100,000 population. 4 REQUEST NO.5 5 Please admit that the 1996 national murder rate in the U.S. 6 was approximately 7.4 per 100,000 population. 7 REQUEST NO.6 8 Please admit that, as reported in the FBI's 1998 Uniform 9 Crime Reports (released in October, 1999), the 1998 national 10 murder rate in the U.S. was 6.3 per 100,000 population. 11 REQUEST NO.7 12 Please admit that, as reported in the FBI's 1998 Uniform 13 Crime Reports (released in October, 1999), from 1997 to 1998 the 14 overall violent crime rate in the U.S. decreased by 7.3 percent. 15 REQUEST NO.8 16 Please admit that, as reported in the FBI's 1998 Uniform 17 Crime Reports (released in October, 1999), from 1997 to robbery declined by 11.3 percent to per 100,000 population, 19 the lowest rate since REQUEST NO.9 Please admit that, as reported in the FBI's 1998 Uniform 22 Crime Reports (released in October, 1999), the rate at which 23 firearms were actually used to commit murder decreased from in 1997 to 64.9 in / / / 26 / / / 27 / / / REQUESTS FOR ADMISSION, SET ONE c:\legal\casefile\118-excel\2-sf\discover\rfa1.plt

4 1 REQUEST NO Please admit that, as reported in the FBI's 1998 Uniform 3 Crime Reports (released in October, 1999), the rate at which 4 firearms were used to commit robbery decreased from 39.7 in to 38.2 in REQUEST NO Please admit that between 1993 and 1998, the murder rate in 8 California has decreased by approximately the same amount as the 9 decrease in the national murder rate. 10 REQUEST NO Please admit that PLAINTIFFS contend approximately million new handguns are produced, marketed and distributed in 13 the U.S. each year. [See PLAINTIFFS' first amended complaint, 14 Paragraph 25] 15 REQUEST NO Please admit that PLAINTIFFS contend that from 1993 to approximately 15 million new handguns were produced, marketed and 18 distributed in the U.S. 19 REQUEST NO Please admit that, as reported in the F.B.I.'s Uniform Crime Reports, the annual number of murders in the U.S. dropped from 22 24,526 in 1993 to 16,914 in REQUEST NO Please admit that the fact the U.S. murder rate decreased 25 between 1993 and 1998, while the number of handguns owned by 26 private citizens increased, shows that increasing numbers of 27 handguns does not lead to higher murder rates REQUESTS FOR ADMISSION, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\RFA1.PLT

5 1 REQUEST NO Please admit that the fact the U.S. murder rate decreased 3 between 1993 and 1998, while the number of handguns owned by 4 private citizens increased, shows that increasing the number of 5 handguns owned by the public reduces the murder rate. 6 REQUEST NO Please admit that Nevada has had a lower murder rate than 8 does California over the past five years. 9 REQUEST NO Please admit that Arizona has had a lower murder rate than 11 does California over the past five years. 12 REQUEST NO Please admit that the sale and distribution of firearms 14 referred to in Paragraph 29 of PLAINTIFFS' first amended 15 complaint is fully regulated by federal and state law. 16 REQUEST NO Please admit that most police departments in the U.S. have 18 switched from revolvers, with six bullets stored in a rotating 19 cylinder that could not be reloaded quickly, to semi-automatic 20 pistols with bullets stored in magazines. REQUEST NO. 22 Please admit that those states which make it easier for 23 their citizens to carry concealed weapons have lower rates or 24 violent crime and murder. 25 / / / 26 / / / 27 / / / REQUESTS FOR ADMISSION, SET ONE C;\Legal\casefile\118-Excel\2-SF\Discover\RFA1.PLT

6 1 REQUEST NO Please admit that the "personalized safety technology" 3 referred to in Paragraph 65 of PLAINTIFFS' first amended 4 complaint would prevent the use of a firearm by anyone other than 5 the one person for whom it had been "personalized. 6 REQUEST NO Please admit that the "personalized safety technology" 8 referred to in Paragraph 65 of PLAINTIFFS' first amended 9 complaint would prevent the use of a firearm by anyone other than 10 the one person for whom it had been "personalized," even in an 11 emergency, self-defense situation. 12 REQUEST NO Please admit that the "personalized safety technology" 14 referred to in Paragraph 65 of PLAINTIFFS' first amended 15 complaint would prevent the person for whom it had been 16 "personalized" from having the option of using either hand to 17 discharge the firearm. 18 REQUEST NO Please admit there is no known case in California of a 20 firearm discharging itself without human involvement. REQUEST NO Please admit there is no known case in California of a 23 firearm "victimizing California residents" on its own and without 24 human involvement. 25 I I I 26 I I I 27 I I I REQUESTS FOR ADMISSION, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\RFAl.PLT

7 1 REQUEST NO Please admit there is no difference in the FUNCTIONING of 3 "assault weapons" referred to in Paragraph 48 of PLAINTIFFS' 4 first amended complaint, as compared to the FUNCTIONING of other 5 semi-automatic firearms not considered to be ~assault weapons." 6 7 Dated: October 22, 1999 THE STEVEN A. SILVER By: EXCEL REQUESTS FOR ADMISSION, SET ONE C;\Legal\casefile\118-Excel\2-SF\Discover\RFA1.F1T

8 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF TULARE. 3 I am employed in the County of Tulare, State of California. 4 I am over the age of 18 and not a party to the within action; my business address is 1077 W. Morton Avenue, Suite C, 5 Porterville, California On October 22, 1999, I served the foregoing document described as REQUESTS FOR ADMISSION on the interested parties in 7 this action by placing a true copy thereof enclosed in an envelope addressed as follows: 8 SEE ATTACHED SERVICE LIST 9 BY FACSIMILE (Please see Facsimile Cover Sheet) 10 BY FEDERAL EXPRESS 11 [X] BY MAIL. I am "readily familiar" with my firm's practice of 12 collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal service on that 13 same day with postage thereon fully prepaid at Porterville, California, in the ordinary course of business. I am aware that 14 on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one 15 day after date of deposit for mailing in affidavit. 16 Executed on October 22, 1999, at Porterville, California. 17 I declare under penalty of perjury under the laws of the State of California that the above t e and t REQUESTS FOR ADMISSION, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\RFAl.PLT

9 1 2 SERVICE LIST Case Name San Francisco County Superior Court Case No DEFENDANTS Robert C. Gebhardt, Esq. 4 Craig A. Livingston, Esq. SCHNADER, HARRISON, SEGAL & LEWIS, LLP California Street, Suite 1200 San Francisco, CA Attorneys for Defendant BERETTA U.S.A. CORP. 7 Ralph W. Robinson, Esq. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER California Street, Suite 1400 San Francisco, CA Attorneys for Defendant SIGARMS, INC. 10 K.D. Kirwin, Esq. Robert N. Tafoya, Esq. 11 AKIN, GUMP, STRAUSS, HAUER & FELD, LLP 2029 Century Park East, Suite Los Angeles, CA Attorneys for Defendant H&R 1871, INC., BROWNING ARMS CO., and 13 KEL-TEC CNC INDUSTRIES, INC., HI - POINT FIREARMS 14 James C. Sabalos, Esq. LAW OFFICES OF JAMES C. SABALOS Newport Center Dr., Suite 530 Newport Beach, CA Attorneys for BRYCO ARMS, INC., and B.L. JENNINGS, INC. 17 Rex Heeseman, Esq. Lawrence J. Kouns, Esq. 18 Christopher J. Healey, Esq. LUCE, FORWARD, HAMILTON & SCRIPPS, LLP S. Figueroa Street, Suite 3600 Los Angeles, CA Attorneys for Defendant STURM, RUGE~ & COMPANY, INC., and SMITH & WESSON CORP. Charles L. Coleman, III, Esq. 22 Mark L. Venardi, Esq. HOLLAND & KNIGHT, LLP Montgomery Street, Suite 4050 San Francisco, CA Attorneys for Defendant HECKLER & KOCH, INC. 25 Nicholas Heldt, Esq. Diane T. Gorczyca, Esq. 26 SEDGWICK, DETERT, MORAN & ARNOLD One Embarcadero Center, 16 th Floor 27 San Francisco, CA Attorneys for Defendant RSR WHOLESALE GUNS, INC :REQUESTS FOR ADMISSION, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\RFAl.PLT

10 1 Manuela Albuquerque, Esq. Matthew J. Orebic 2 OFFICE OF THE CITY ATTORNEY 1947 Center Street, 1 st Floor 3 Berkeley, Ca Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 4 the City of Berkeley 5 Richard E. Winnie, Esq. Kristen J. Thorsness, Esq. 6 OFFICE OF ALAMEDA COUNTY COUNSEL 12 Oak Street, Room Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 8 the COUNTY OF ALAMEDA 9 Jayne W. Williams, Esq. Randolph W. Hall, Esq. 10 Joyce M. Hicks, Esq. R. Manuel Fortes, Esq. 11 J. Patrick Tang, Esq. OFFICE OF THE CITY ATTORNEY 12 One Frank Ogawa Plaza, 6 th Floor Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and the CITY OF OAKLAND 14 Michael S. Lawson, Esq. 15 EAST PALO ALTO CITY ATTORNEY 1600 Broadway, Suite Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 17 the CITY OF EAST PALO ALTO I REQUESTS FOR ADMISSION, SET ONE c:\legal\casefile\118-excel\2-sf\discover\rfa1.plt

11 ATTORNEY OR PARlY WITHOUT ATTORNEY (Name, slale bar number, and address): TELEPHONE AND FAX NOS.: I- Steven A. Silver (SBN ) Tel: (559) LAW OFFICES OF STEVEN A. SILVER Fax: (559) W. Morton Avenue, Suite C Porterville, CA ATTORNEY FOR (Name): Defendant EXCEL INDUSTRIES, INC. NAME OF COURT AND JUDICIAL DISTRICT AND BRANCH COURT, IF ANY: San Francisco Superior Court FI 120 SHORT TITLE OF CASE: People of California v. Arcadia Machine & Tool, et al. FORM INTERROGATORIES Asking Party: Defendant EXCEL INDUSTRIES, INC Answering Party: Plaintiffs People of California, Joe Serna, Berkeley, Oakland, et Set No.: One CASE NUMBER: Sec. 1. Instructions to All Parties (a) These are general instructions. For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure section 2030 and the cases construing it. (b) These interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use in the superior courts only. A separate set of interrogatories, Form Interrogatories-Economic Utigation (form FI-129), which have no subparts, are designed for optional use in municipal courts. However, they also may be used in superior courts. See Code of Civil Procedure section 94. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, unless the information is equally available to the asking party. (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer to the interrogatory can be found. (f) Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information. (g) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: "I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (d) The interrogatories in section 16.0, Defendant's Contentions - Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) In superior court actions, an answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 30 days after you are served with these interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared. See Code of Civil Procedure section 2030 for details. (c) Each answer must be as complete and straightforward as the information reasonably available to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible. Fonn Approved by the Judicial Council of California FI 120 [Rev. January ] (Continued) (DATE) Sec. 4. Definitions (SIGNATURE) Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): UJ (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. o (2) INCIDENT means (insert your definition here or on a separate, attached sheet labeled "Sec. 4(a)(2)''): Pago ono of eight FORM INTERROGATORIES Code of Civil Procedure, 2030,

12 (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. o 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. o 16.7 Do you contend that any of the property damage claimed by plaintiff in discovery proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. o 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. o 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; (b) the date each claim arose; (c) the nature of each claim; (d) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. o Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure section 2034)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT Responses to Request for Admissions I1[J 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing How the Incident Occurred - Motor Vehicle o 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). o 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; (c) the name, ADDRESS, and telephone number of each occupant other than the driver; (d) the name, ADDRESS, and telephone number of each registered owner; (e) the name, ADDRESS, and telephone number of each lessee; (f) the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder; (g) the name of each owner who gave permission or consent to the driver to operate the vehicle. o 20.3 State the ADDRESS and location where your trip began, and the ADDRESS and location of your destination. o 20.4 Describe the route that you followed from the beginning of your trip to the location of the INCIDENT, and state the location of each stop, other than routine traffic stops, during the trip leading up to the INCIDENT. D 20.5 State the name of the street or roadway, the lane of travel, and the direction of travel of each vehicle involved in the INCIDENT for the 500 feet of travel before the INCIDENT. (Continued) FI 120 [Rev. January 1, 1998J FORM INTERROGATORIES Page seven of eight

13 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF TULARE. 3 I am employed in the County of Tulare, State of California. 4 I am over the age of 18 and not a party to the within action; my business address is 1077 W. Morton Avenue, Suite C, 5 Porterville, California On Ootober 22, 1999, I served the foregoing document described as FORM INTERROGATORIES, SET ONE on the interested 7 parties in this action by placing a true copy thereof enclosed in an envelope addressed as follows: 8 SEE ATTACHED SERVICE LIST 9 BY FACSIMILE (Please see Facsimile Cover Sheet) 10 BY FEDERAL EXPRESS 11 [X] BY MAIL. I am "readily familiar" with my firm's practice of 12 collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal service on that 13 same day with postage thereon fully prepaid at Porterville, California, in the ordinary course of business. I am aware that 14 on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one 15 day after date of deposit for mailing in affidavit. 16 Executed on Ootober 22, 1999, at Porterville, California I declare under penalty State of California that the of perjury under the laws of above is tfu;, nd correct. ~". STEVEN A. -1- FORM INTERROGATORY NO. 17.1, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\FORM-ROG-17.1

14 1 SERVICE LIST Case Name 2 San Francisco County Superior Court Case No DEFENDANTS Robert C. Gebhardt, Esq. 4 Craig A. Livingston, Esq. SCHNADER, HARRISON, SEGAL & LEWIS, LLP California Street, Suite 1200 San Francisco, CA Attorneys for Defendant BERETTA U.S.A. CORP. 7 Ralph W. Robinson, Esq. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER California Street, Suite 1400 San Francisco, CA Attorneys for Defendant SIGARMS, INC. 10 K.D. Kirwin, Esq. Robert N. Tafoya, Esq. 11 AKIN, GUMP, STRAUSS, HAUER & FELD, LLP 2029 Century Park East, Suite Los Angeles, CA Attorneys for Defendant H&R 1871, INC., BROWNING ARMS CO., and 13 KEL-TEC CNC INDUSTRIES, INC., HI-POINT FIREARMS 14 James C. Sabalos, Esq. LAW OFFICES OF JAMES C. SABALOS Newport Center Dr., Suite 530 Newport Beach, CA Attorneys for BRYCO ARMS, INC., and B.L. JENNINGS, INC. 17 Rex Heeseman, Esq. Lawrence J. Kouns, Esq. 18 Christopher J. Healey, Esq. LUCE, FORWARD, HAMILTON & SCRIPPS, LLP S. Figueroa Street, Suite 3600 Los Angeles, CA Attorneys for Defendant STURM, RUGER & COMPANY, INC., and SMITH & WESSON CORP. Charles L. Coleman, III, Esq. 22 Mark L. Venardi, Esq. HOLLAND & KNIGHT, LLP Montgomery Street, Suite 4050 San Francisco, CA Attorneys for Defendant HECKLER & KOCH, INC. 25 Nicholas Heldt, Esq. Diane T. Gorczyca, Esq. 26 SEDGWICK, DETERT, MORAN & ARNOLD One Embarcadero Center, 16 th Floor 27 San Francisco, CA Attorneys for Defendant RSR WHOLESALE GONS, INC FORM INTERROGATORY NO. 17.1, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\FORM-ROG-17.1

15 1 Michael J. Bonesteel, Esq. Steven L. Hoch, Esq. 2 Carolyn Trokey, Esq. HAIGHT, BROWN & BONESTEEL, LLP th Street, Suite 4000 Santa Monica, CA Attorneys for Defendant NORTH AMERICAN ARMS, INC. 5 Michael St. Peter, Esq. D. Scott Shaffer, Esq. 6 Charles S. Park, Esq. THE ST. PETER LAW GROUP 7 Three Embarcadero Center, Suite 2900 San Francisco, CA Attorneys for Defendant COLT'S MANUFACTURING CO., INC. 9 Wendy E. Schultz, Esq. Norman J. Watkins, Esq. 10 LYNBERG & WATKINS 888 S. Figueroa Street, 16 th Floor 11 Los Angeles, CA Attorneys for Defendants NAVEGAR, INC., PHOENIX ARMS, FORJAS 12 TAURUS, S.A. and TAURUS INTERNATIONAL MANUFACTURING, INC. 13 Charles F. Preuss, Esq. Karene I. Alvarado, Esq. 14 PREUSS, WALKER & SHANAGHER, LLP 225 Bust Street, 16~ Floor 15 San Francisco, CA Attorneys for Defendants ELLETT BROTHERS, INC., MKS SUPPLY, INC., 16 and SOUTHERN OHIO GUN DISTRIBUTORS 17 Stephen C. Mancini, Esq. Susan L. Caldwell, Esq. 18 KOLESTSKY, MANCINI, FELDMAN & MORROW 3460 Wilshire Blvd., 8 th Floor 19 Los Angeles, CA Attorneys for Defendants AMERICAN SHOOTING SPORTS COUNCIL, INC., 20 NATIONAL SHOOTING SPORTS FOUNDATION, INC., and SHOOTING ARMS AND AMMUNITION MANUFACTURER'S INSTITUTE James Leonard Crew, Esq. 22 Jack Leavitt, Esq. 18 Crow Canyon Court, Suite San Ramon, CA Attorneys for Defendant TRADERS SPORTS, INC FORM INTERROGATORY NO. 17.1, SET ONE C:\Legal\casefile\118-Excel\2-SF\Discover\FORM-ROG-17.l

16 1 PLAINTIFFS Louise H. Renne, Esq. 2 Patrick J. Mahoney, Esq. Owen J. Clements, Esq. 3 D. Cameron Baker, Esq. Ingrid M. Evans, Esq. 4 David F. Campos, Esq. SAN FRANCISCO CITY ATTORNEY'S OFFICE Market Street, 6~ Floor San Francisco, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 7 Patrick J. Coughlin, Esq. Michael J. Dowd, Esq. 8 MILBERG, WEISS, BERSHAD, HYNES & LERACH, LLP 600 W. Broadway, Suite San Diego, CA 901 Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 10 Richard M. Heimann, Esq. 11 Robert J. Nelson, Esq. LIEFF, CABRASER, HEIMANN & BERNSTEIN 12 Embarcadero Center West San Francisco, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 14 Alan M. Caplan, Esq. Philip Newmark, Esq. 15 Paul R. Hoeber, Esq. BUSHNELL, CAPLAN & FIELDING 16 2 Pine Street, Suite 600 San Francisco, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 18 McCue & McCue 600 W. Broadway, Suite San Diego, CA 901 Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 20 Thomas F. Casey, III, Esq. Brenda B. Carlson, Esq. OFFICE OF THE COUNTY COUNSEL County Center Redwood City, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA 24 Samuel L. Jackson, Esq. Gloria Zarco, Esq. 25 OFFICE OF THE CITY ATTORNEY th Street, 10 th Floor 26 Sacramento, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 27 Joe Serna, Jr FORM INTERROGATORY NO. 17.1, SET ONE c:\legal\casefile\118-excel\2-sf\discover\form-rog-17.1

17 j, 1 Manuela Albuquerque, Esq. Matthew J. Orebic 2 OFFICE OF THE CITY ATTORNEY 1947 Center Street, pt Floor 3 Berkeley, Ca Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 4 the City of Berkeley 5 Richard E. Winnie, Esq. Kristen J. Thorsness, Esq. 6 OFFICE OF ALAMEDA COUNTY COUNSEL 12 Oak Street, Room Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 8 the COUNTY OF ALAMEDA 9 Jayne W. Williams, Esq. Randolph W. Hall, Esq. 10 Joyce M. Hicks, Esq. R. Manuel Fortes, Esq. 11 J. Patrick Tang, Esq. OFFICE OF THE CITY ATTORNEY 12 One Frank Ogawa Plaza, 6 th Floor Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and the CITY Og OAKLAND 14 Michael S. Lawson, Esq. 15 EAST PALO ALTO CITY ATTORNEY 1600 Broadway, Suite Oakland, CA Attorneys for Plaintiff THE PEOPLE OF THE STATE OF CALIFORNIA and 1 7 the CITY OF EAST PALO ALTO FORM INTERROGATORY NO. 17.1, SET ONE c:\legal\casefile\118-excel\2-sf\discover\form-rog-17.1