export const rogInstructions = [
  {
    id: "c42293a4-77fd-4c1f-926d-72c36af01298",
    text: "These requests are continuing in nature and require you to file supplementary or amended responses if you obtain further, different or contradictory information at any time prior to a trial of this action.",
  },
  {
    id: "17822ae2-d8ae-4d76-aff6-2c0740d7ba0e",
    text: "Unless otherwise stated, these requests refer to the time, place, and circumstances of the occurrences described and/or complained of in the Complaint and which form the basis for this action.",
  },
  {
    id: "959f3415-92b1-41f3-8954-b69f186d3988",
    text: "Where name and identity of a person is required, state the full name, home address and business address, if known.",
  },
  {
    id: "5ac2d7bb-183d-4e88-91cf-f3fe11810d73",
    text: "When the identity of a corporation or other business entity is requested, state the entity's principal place of business, address and telephone number.  Also, set forth the individual or individuals with knowledge of the facts and circumstances that form the basis for this action.",
  },
  {
    id: "530e79d2-fa37-4ac0-97de-66a4fa5db5a9",
    text: "Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and, unless privileged,  attorneys. ",
  },
  {
    id: "031da6a5-808b-4cd2-aaaa-f4d72d1e549c",
    text: "Where the respondent is a corporation or other business entity, state the name, address and title of persons supplying the information and making the affidavit, and state with particularity the source of his or her information and basis of knowledge.",
  },
  {
    id: "15f855ea-2a7b-4f3d-878b-9c0749ca8e44",
    text: "If you are unable to provide an accurate answer to an interrogatory, or are uncertain regarding a response to any item, please provide your best estimate of the information requested, specifying that the answer is merely an estimate, and that an accurate response cannot be given by you to the item.",
  },

  {
    id: "695ec39a-078a-4c43-b9ba-93403a14a0bb",
    text: "If you withhold any information or documents on the basis of privilege, confidentiality, relevance, or for any other reason whatsoever  please identify it, providing sufficient information to identify the withheld documents or items for this party and the Court to determine whether the documents, items or information should be disclosed.",
  },
];

export const rogDefinitions = [
  {
    text: '"And" and "or" have both conjunctive and disjunctive meanings as necessary to bring within the scope of each request all documents and information that might otherwise be construed to be outside its scope."',
  },
  {
    id: "545bff8d-66de-47fd-9f01-26c945ba8db3",
    text: "'You' refers to the party to whom the requests are addressed and any additional parties or entities as described in the foregoing instructions and these definitions.",
  },
  {
    id: "f218a1f6-4d21-4b53-b1c2-69e2d60b95bb",
    text: "“Person”, unless otherwise specified”, includes the plural as well as the singular, and includes in its meaning any natural person, or artificial or legal entity, including corporations, partnerships, joint ventures, associations, governmental agencies, groups, organizations, and any and every other form of entity cognizable at law.",
  },
  {
    id: "dda1376c-3d42-471f-9cb8-4a1ecb9c10cc",
    text: "“Document” means and includes all written and graphic matter of every kind and description, whether printed or produced by any mechanical, digital or other process, or by hand, whether final draft or reproduction, whether in the actual or constructive possession, custody or control of the respondent to a given interrogatory.  This includes any and all written letters, correspondence, memoranda, notes, statements, transcripts, files, charters, articles of incorporation, securities, bonds, stocks, certificates of deposit, evidences of debt, contracts, agreements, licenses, memoranda or notes of telephone or personal conversations, work papers, tapes, charts, reports, books, ledgers, telegrams, sound recordings, books of account, customer account statements, financial statements, catalogs, checks, check stubs, and written statements of witnesses or other persons having knowledge pertaining to the pertinent facts requested or relating to the interrogatory or subpart thereof, whether or not these documents are claimed to be privileged against disclosure.",
  },
  {
    id: "cc62a598-e50e-4e60-ae3a-9163dd73f8a5",
    text: '“Describe" means a complete statement of all facts known to you about an incident, event, physical object, person, or other subject matter, together with any expert opinions about the subject matter, the basis for those opinions, and a description of all relevant documents and evidence that supports and/or refutes the fact or opinion.',
  },
  {
    id: "05970162-1b13-4f98-ac73-91da0c8f0bf4",
    text: "“Identify” means, when used with reference to an individual person, organization, corporation or association, to state the full name, home and work addresses, e-mail address, home and business telephone numbers, present or last known position and business affiliation and position both in the past and at the time said interrogatory or subpart thereof is being responded to.",
  },
  {
    id: "f4bd002b-08b7-429c-9b1c-c068de17d22c",
    text: "The term “identify” further means, when used with reference to a document, to state the date it was created, its author, the signatory, if different, the addressee, the recipient of all copies, the type of document (e.g. chart, memorandum, letter, or other written document) and its present or last known custodian.",
  },
  {
    id: "",
    text: '"Refer to" or "refers to" means mentioning, discussing, making reference to or relating to in any way.',
  },
  {
    id: "8ff2c80e-7dd8-4c48-b202-8702047c4946",
    text: '"Relate(s) to" or "relating to" means constituting, defining, concerning, embodying, reflecting, identifying, stating, referring to, bearing upon, dealing with or in any way pertaining to.',
  },
];

export const foundationRogs = [
  {
    id: "81094bfb-07d4-4b46-bc73-641ab62ce80b",
    text: "State your full name, home addresses for the past ten years, your employer for the last 10 years, your current work address, date of birth and social security number.",
  },
  {
    id: "fb50e08b-2009-4588-89b8-4842481f434a",
    text: "Identify all insurance carriers or self-insured funds, by name, address, policy numbers and policy limits for any insurance policy or fund which may provide coverage for any judgment entered against you in this action.",
  },
  {
    id: "72680c6f-4d7e-4e6b-a932-477e0392db98",
    text: "If you contend that any other entity or person, including any other party or the Plaintiff, was responsible for the occurrence and Plaintiff's damages, identify such person(s) or entities, and give a concise statement of the facts upon which you rely in support of your contention.",
  },
  {
    id: "6933ce23-8c88-4c6b-877c-c59629685ea1",
    text: "Identify all experts who will be called to testify at a trial on the merits of this action, the subject matter and substance of such testimony, a summary of the grounds for each opinion; and produce any written report made by the expert concerning those findings and opinions.",
  },
  {
    id: "ec035502-b3bc-436f-b517-b77721a97b58",
    text: " Identify any documents and recordings including, but not limited to, pictures, photographs, PowerPoint presentations for use at trial, demonstrative exhibits, computer generated exhibits, electronically stored data, visual aids, overlays, employment records, plats, visual recorded images, audio recordings, cassette tapes, transcripts of testimony, diagrams and objects relative to the occurrence, the scene of the occurrence, Plaintiff’s physical condition or statements made by any party or witness. Identify the substance of the item, the date obtained, what is depicted within the item, and the name and address of the present custodian of each item.",
  },
  {
    id: "ae5e13e3-1296-4d89-a873-8949be9d7bcf",
    text: "If you, your insurance carrier, private investigator, or any other person or entity is in possession of any written, oral or recorded statements by any party or person with personal knowledge relative to the occurrence, indicate the date and time each statement was obtained, the name and address of each person who provided the statement, the contents of the statement, and the name and address of the current custodian of the statement.",
  },
  {
    id: "e2c7bb8d-48cf-47e9-b27d-e872dcffdd3d",
    text: "Describe any conduct, comment, conversation, statement, or report made by any person at the scene of the occurrence or at any time, concerning fault for the occurrence or facts relevant to any issue in this case. Include in your answer where the conduct, comment, conversation, or statement took place, and in whose presence it was made/observed, as well as the name of the author of such statement, the present custodian of the statement and the address for the custodian.",
  },
  {
    id: "4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
    text: "Since your eighteenth birthday, when you were represented by an attorney or waived the right to be represented by an attorney, state whether you have been found guilty of, or plead guilty to, any crimes other than minor traffic violations (i.e., those traffic offenses without the potential penalty of incarceration) and, if so, state the nature of the offense, the date of each conviction, and the full name of the court where each conviction was entered.",
  },
  {
    id: "4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
    text: "If you are aware of any other case or proceeding involving the occurance identified in the Complaint including, but not limited to, civil, criminal or administrative actions, identify the case or action by tribunal, case number, docket number or citation number, the date of any hearing, and indicate any pleas in the case(s) and the disposition of the matter(s).",
  },
];

export const standardProd = [
  {
    id: "e0863692-c5da-4516-b85c-233a7f811a34",
    text: "All documents identified, directly or indirectly, in your answers to Interrogatories.",
    index: 0,
  },
  {
    id: "0d648f06-b6f9-4264-bcf2-c3111fe3f976",
    text: "All written reports of all expert witnesses with whom you or your attorneys have consulted, including but not limited to those  you expect to and/or have identified as persons you will call as expert witnesses at any trial of this action.",
    index: 1,
  },
  {
    id: "8c8573de-1a5c-4828-ba99-d51f610136a5",
    text: "All documents upon which any expert witness you intend to call at trial relied upon in formulating an opinion about the subject matter of this action.",
    index: 2,
  },
  {
    id: "63ab0999-c877-4ebc-9094-6d343294411d",
    text: "The most recent curriculum vitae of each expert whom you expect to call as an expert witness at trial.",
    index: 3,
  },
  {
    id: "5b3ac105-c026-4f37-b335-2ab83adb6658",
    text: "All notes, correspondence, bills, invoices, diagrams, photographs, or other documents prepared or reviewed by each person whom you expect to call as an expert witness at trial.",
    index: 4,
  },
  {
    id: "eb382a63-1c0b-4a78-9bba-d67380bb6367",
    text: "All invoices generated by expert witnesses for performing  expert witness services to you, including but not limited to fees for medical examination,  records review,  pretrial preparation, any telephone conference, any trial testimony anticipated and any other fee paid to experts.",
    index: 5,
  },
  {
    id: "a07bbc03-2f14-4837-965b-67ee261f25e4",
    text: "Any and all written, recorded, or signed statements of any party, including the plaintiff, defendant, witnesses, investigators, or agent, representative or employee of the parties concerning the subject matter of this action.",
    index: 6,
  },
  {
    id: "495b094d-36f2-4a83-971e-54b1b5312515",
    text: "All documents, photographs, videotapes or audio tapes, digital recordings or recordings in any medium, diagnostic images, diagrams, records, surveys or other graphic representations of information concerning the subject matter/occurrences that form the basis of this action.",
    index: 7,
  },
  {
    id: "cdcc44cf-13b2-4011-adb5-ed435156a0f8",
    text: "Any documents which afforded, described or pertained to liability insurance coverage for the occurrences which are the subject matter of the complaint.",
    index: 8,
  },
  {
    id: "7b85bf1d-ce31-4cb5-baac-b678f3afb418",
    text: "Any documents identified or described in any other parties' answers to Interrogatories that are in your possession, custody or control.",
    index: 9,
  },
  {
    id: "5b2033f9-2d14-49d4-848a-8c3630bb78d8",
    text: "Any documents received pursuant to a subpoena duces tecum or a request under the Freedom of Information Act in this case.",
    index: 10,
  },
  {
    id: "fe9ce1d8-265f-4ebc-9856-99715cbb23ee",
    text: "Any document prepared during the regular course of business as a result of the occurrence complained of in the complaint.",
    index: 11,
  },
  {
    id: "0012041e-8618-4864-b084-9c354261731a",
    text: "Copies of any treaties, standards in the industry, legal authority, rule, case, statute, or code that will be relied upon in the prosecution of this action.",
    index: 12,
  },
];
