Notes

The term “DESCRIBE” with respect to any communication, act, or conduct, means to
give, state, or identify the following:
a. The date of communication, act, or conduct;
b. Where such communication, act, or conduct took place;
c. The PERSON or PERSONS present;
d. If the words or substance of the communication, the PERSON making each of the
particular statements so listed, the mode of communication, and the location of each of the
participants;
e. If an act or conduct, the details of the act or conduct being described and what
each PERSON participating in such an action or conduct did;
f. The PERSON or PERSONS on whose recollection or response the interrogatory
calling for a description is based, and the source of the PERSON’S knowledge;
g. Any other PERSON or PERSONS having knowledge of the fact given in response
to or called for by the interrogatory requesting you to describe the communication, act, or
conduct; and
h. Any DOCUMENTS reflecting, embodying, or relating to any communication, act,
or conduct described in response to or called for by the interrogatory requesting you to describe
the communication, act, or conduct.
i. The term “INCIDENT” means Plaintiff T.T.’s interactions with Defendant County
of San Diego and any of its social workers, Mary Spurlock, Gabrielle (Ms. Spurlock’s teenage
niece), and the older adult male (referenced as “Daddy”) as described in paragraphs 16 through
77 of Plaintiff’s Complaint (“Complaint”), including all circumstances and events surrounding
or resulting from the alleged placement of Plaintiff in the home of Mary Spurlock, child abuse
investigations, and purported abuse as described in the Complaint.
The term “ADDRESS” means the street address, including the city, state and zip code.
SPECIAL INTERRROGATORIES
SPECIAL INTERROGATORY NO. 1:
Please state the names and dates of birth of all YOUR children.
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SPECIAL INTERROGATORY NO. 2:
For each child identified in YOUR response to Special Interrogatory No. 1 above, please
state whether YOU have legal and/or physical custody of that child.
SPECIAL INTERROGATORY NO. 3:
For each child identified in YOUR response to Special Interrogatory No. 1 above, please
state whether YOUR legal and/or physical custody of that child was terminated, suspended or
restricted by a court in the last ten (10) years and identify the dates your parental rights were
terminated, suspended or restricted, if applicable.
SPECIAL INTERROGATORY NO. 4:
Please state the names, dates of birth, and last known address and telephone of all YOUR
current and previous spouses.
SPECIAL INTERROGATORY NO. 5:
For each spouse identified in YOUR response to Special Interrogatory No. 4, please state
the date of marriage, divorce, and/or separation, if applicable.
SPECIAL INTERROGATORY NO. 6:
Please IDENTIFY all PERSON(S) YOU spoke with concerning the INCIDENT.
SPECIAL INTERROGATORY NO. 7:
For each PERSON identified in YOUR response to Special Interrogatory No. 6, please
DESCRIBE YOUR conversation with that PERSON concerning the INCIDENT.
SPECIAL INTERROGATORY NO. 8:
If YOU are aware of any written or recorded material (such as notes, journal or diary
entries, reports, summaries, audio or video recordings, electronically stored information, social
media posts, or photographs) discussing the INCIDENT, please IDENTIFY the material and
state who has custody of it.
SPECIAL INTERROGATORY NO. 9:
From the period of time immediately after the INCIDENT to present, If YOU are or were
in possession of a driver’s license and/or permit for the operation of a motor vehicle, please state
the issuing entity, license number and type, date of issuance, and all restrictions, if any.
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SPECIAL INTERROGATORY NO. 10:
From the period of time immediately after the INCIDENT to present, if YOU are or were
in possession of any professional certification or business license, please state the issuing entity,
certification or license number and type, date of issuance, and all restrictions, if any.
SPECIAL INTERROGATORY NO. 11:
From the period of time immediately after the INCIDENT to present, was there in effect
any policy of insurance through which YOU were or might be insured in any manner (for
example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the
damages, claims, or actions that have arisen out of the INCIDENT?
SPECIAL INTERROGATORY NO. 12:
In YOUR response to Special Interrogatory No. 11, for each policy, please state:
(a) the kind of coverage;
(b) the name and ADDRESS of the insurance company;
(c) the name, ADDRESS, and telephone number of each named insured;
(d) the policy number;
(e) the limits of coverage for each type of coverage contained in the policy;
(f) Whether any reservation of rights or controversy or coverage dispute exists between
YOU and the insurance company; and
(g) The name, ADDRESS, and telephone number of the custodian of the policy.
SPECIAL INTERROGATORY NO. 13:
From the date(s) of the INCIDENT to September 12, 2012, have YOU filed an action or
made a written claim or demand for compensation for YOUR personal injuries? If so, for each
action, claim, or demand state:
(a) the date, time, and place and location (closest street ADDRESS or intersection) of the
incident giving rise to the action, claim, or demand;
(b) the name, ADDRESS, and telephone number of each PERSON against whom the
claim or demand was made or the action filed;
(c) the court, names of the parties, and case number of any action filed;
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(d) the name, ADDRESS, and telephone number of any attorney representing YOU;
(e) whether the claim or action has been resolved or is pending; and
(f) a description of the injury.
SPECIAL INTERROGATORY NO. 14:
From the date(s) of the INCIDENT to September 12, 2012, have YOU made a written
claim or demand for workers’ compensation benefits? If so, for each claim or demand state:
(a) the date, time, and place and location of the incident giving rise to the claim;
(b) the name, ADDRESS, and telephone number of YOUR employer at the time of the
injury;
(c) the name, ADDRESS, and telephone number of the workers’ compensation insurer
and the claim number;
(d) the period of time during which YOU received workers’ compensation benefits; and
(e) a description of the injury;
(f) the name, ADDRESS, and telephone number of any health care provider who
provided services; and
(g) the case number at the Workers’ Compensation Appeals Board.
SPECIAL INTERROGATORY NO. 15:
From the date(s) of the INCIDENT to present, have YOU ever received treatment from
any licensed professional/healthcare provider (including but not limited to doctors, therapists,
counselors, clinical social workers, psychologists, psychiatrists, and psychotherapists) for any
emotional or mental health condition? If so, IDENTIFY the name and address of the treatment
provider, dates of treatment, the nature of treatment, the condition for which YOU were treated,
and any diagnoses YOU received.
SPECIAL INTERROGATORY NO. 16:
Please state all facts that support YOUR contention that the COUNTY was “informed
that T.T. was being sexually abused in Ms. Spurlock’s foster care” and that the COUNTY
“observed and/or were informed of T.T’s sexualized and/or aggressive behavioral issues” as
alleged in paragraph 56 of the Complaint.
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SPECIAL INTERROGATORY NO. 17:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 56 of the Complaint.
SPECIAL INTERROGATORY NO. 18:
Please state all facts that support YOUR contention that the COUNTY “(1) refused
and/or failed to reasonably and/or adequately investigate the abuse allegations, (2) ignored the
sexual abuse allegations, (3) allowed T.T to remain in Ms. Spurlock’s care, (4) continued to
approve Ms. Spurlock as a foster parent, (5) approved Ms. Spurlock’s guardianship of T.T., (6)
failed to conduct an adequate background check on Ms. Spurlock’s household and the adults
residing therein, (7) refused and/or failed to set up appropriate safeguards to protect T.T., and/or
(8) refused and/or failed to provide T.T. minimally adequate psychotherapeutic care targeting
the severe trauma she sustained as a result of past sexual abuse” as alleged in paragraph 57 of
the Complaint.
SPECIAL INTERROGATORY NO. 19:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 57 of the Complaint.
SPECIAL INTERROGATORY NO. 20:
Please state all facts that support YOUR contention that the COUNTY’s “acts, omissions,
and/or failure to setup adequate safeguards, allowed T.T. sexual abuse to occur and/or continue”
as alleged in paragraph 58 of the Complaint.
SPECIAL INTERROGATORY NO. 21:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 58 of the Complaint.
SPECIAL INTERROGATORY NO. 22:
Please state all facts that support YOUR contention that “T.T. would not have faced any
sexual abuse” if the COUNTY “had fulfilled their duties and responsibilities, and/or provided
adequate protection and safety” and the COUNTY’s “failure to provide T.T. minimally adequate
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psychotherapeutic care exacerbate T.T.’s lasting psychological injuries” as alleged in paragraph
59 of the Complaint.
SPECIAL INTERROGATORY NO. 23:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contention in paragraph 59 of the Complaint.
SPECIAL INTERROGATORY NO. 24:
Please state all facts that support YOUR contention that “Plaintiff sustained physical
injuries” as a result of the COUNTY’s “negligence and inadequate supervision” as alleged in
paragraph 60 of the Complaint.
SPECIAL INTERROGATORY NO. 25:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 60 of the Complaint.
SPECIAL INTERROGATORY NO. 26:
Please state all facts that support YOUR contention that “Plaintiff sustained
psychological, mental, and/or emotional injuries” as alleged in paragraph 61 of the Complaint.
SPECIAL INTERROGATORY NO. 27:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 61 of the Complaint.
SPECIAL INTERROGATORY NO. 28:
Please state all facts that support YOUR contention that the COUNTY’s “negligence was
a substantial factor in causing Plaintiff’s harm” as alleged in paragraph 62 of the Complaint.
SPECIAL INTERROGATORY NO. 29:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 62 of the Complaint.
SPECIAL INTERROGATORY NO. 30:
Please state all facts that support YOUR contention that the COUNTY “refused and/or
failed to take appropriate action to investigate and stop the abuse” and the COUNTY “did not
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report the information and they did not inform others about the known dangers and/or sexual
abuse that T.T. was facing” as alleged in paragraph 67 of the Complaint.
SPECIAL INTERROGATORY NO. 31:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 67 of the Complaint.
SPECIAL INTERROGATORY NO. 32:
Please state all facts that support YOUR contention that the COUNTY “violated and/or
breached mandatory and nondelegable duties” as alleged in paragraph 68 of the Complaint.
SPECIAL INTERROGATORY NO. 33:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 68 of the Complaint.
SPECIAL INTERROGATORY NO. 34:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Welf. & Inst. Code, §361.4 and CDSS MPP Regulations 31-400, 31-405, 31-420, and 31-445,
“by failing to fulfill a social worker’s responsibilities for placement” as alleged in paragraph
69(a) of the Complaint.
SPECIAL INTERROGATORY NO. 35:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contention in paragraph 69(a) of the Complaint.
SPECIAL INTERROGATORY NO. 36:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Welf. & Inst. Code, §328, 16504(a), 16501(d), and/or 16501(f) and/or CDSS MPP Regulations
31-101, 31-105, 31-110, 31-115, 31-120, and/or 31-125, “by failing to investigate or otherwise
respond to the reported instances of child abuse and/or sexual abuse” as alleged in paragraph
69(b) of the Complaint.
SPECIAL INTERROGATORY NO. 37:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(b) of the Complaint.
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SPECIAL INTERROGATORY NO. 38:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-300, 31-320 and 31-330, “by failing to adequately conduct face-to-face
contacts with Plaintiffs” as alleged in paragraph 69(c) of the Complaint.
SPECIAL INTERROGATORY NO. 39:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(c) of the Complaint.
SPECIAL INTERROGATORY NO. 40:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-200 “by failing to perform an assessment on T.T. and/or Ms. Spurlock's
home to include any and all relevant social, cultural, and physical factors that may impact her
placement. And, when placing T.T. in the Ms. Spurlock's home, by failing to assess the
characteristics of the other adults residing within the home” as alleged in paragraph 69(d) of the
Complaint.
SPECIAL INTERROGATORY 41:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(d) of the Complaint.
SPECIAL INTERROGATORY 42:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-501, “by failing to report and/or investigate reports of neglect and/or abuse
of Plaintiffs and other children” as alleged in paragraph 69(e) of the Complaint.
SPECIAL INTERROGATORY 43:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(e) of the Complaint.
SPECIAL INTERROGATORY 44:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-445, “by failing to monitor Plaintiff’s physical and emotional condition,
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and failing to take necessary actions to safeguard the Plaintiff’s growth and development while
in the Ms. Spurlock’s placement” as alleged in paragraph 69(f) of the Complaint.
SPECIAL INTERROGATORY 45:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(f) of the Complaint.
SPECIAL INTERROGATORY 46:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Penal Code, § 11165.9, “by failing to accept reports of suspected child abuse and/or neglect of
Plaintiff without legal justification and did not properly maintain a record of all reports
received” as alleged in paragraph 69(g) of the Complaint.
SPECIAL INTERROGATORY 47:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(g) of the Complaint.
SPECIAL INTERROGATORY 48:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Penal Code, §11164, et seq., §11165.9, §11166, “by failing to report known and/or suspected
neglect and/or abuse of Plaintiff to appropriate authorities and failed to make initial reports or
follow up reports within 36 hours of receiving said reports of abuse and/or neglect” as alleged in
paragraph 69(h) of the Complaint.
SPECIAL INTERROGATORY 49:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(h) of the Complaint.
SPECIAL INTERROGATORY 50:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-201, 31-205, 31-206 and/or Cal. Welf. & Inst. Code, §16501.l(d), “by
failing to conduct an assessment and develop a case plan” as alleged in paragraph 69(i) of the
Complaint.
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SPECIAL INTERROGATORY 51:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(i) of the Complaint.
SPECIAL INTERROGATORY 52:
Please state all facts that support YOUR contention that the COUNTY violated CDSS
MPP Regulations 31-101, 31-105, 31-110, 31-115, 31-120, and/or 31-128 and/or Cal. Welf. &
Inst. Code, § 16504, “by failing to conduct a basic evaluation of risks to determine whether an
emergency situation existed” as alleged in paragraph 69(j) of the Complaint.
SPECIAL INTERROGATORY 53:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(j) of the Complaint.
SPECIAL INTERROGATORY 54:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Welf. & Inst. Code, §16504(a), 1650l(d), and/or 16501(f), “by failing to control the conduct of
Ms. Spurlock, Gabrielle, Daddy, and/or other perpetrators, and/or otherwise protect Plaintiff” as
alleged in paragraph 69(k) of the Complaint.
SPECIAL INTERROGATORY 55:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(k) of the Complaint.
SPECIAL INTERROGATORY 56:
Please state all facts that support YOUR contention that the COUNTY violated Cal.
Welf. & Inst. Code §366 as alleged in paragraph 69(l) of the Complaint.
SPECIAL INTERROGATORY 57:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(l) of the Complaint.
SPECIAL INTERROGATORY 58:
Please state all facts that support YOUR contention that the COUNTY violated Cal
Health & Saf. Code § 1520 as alleged in paragraph 69(m) of the Complaint.
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SPECIAL INTERROGATORY 59:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(m) of the Complaint.
SPECIAL INTERROGATORY 60:
Please state all facts that support YOUR contention that the COUNTY violated Cal. DSS,
Regulations 31-075; 31-101; 31-105; 31-125; 31-205; 31-206; 31-300, 31-310; 31-320; 31-330;
31-400, and 31-405 as alleged in paragraph 69(n) of the Complaint.
SPECIAL INTERROGATORY 61:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(n) of the Complaint.
SPECIAL INTERROGATORY 62:
Please state all facts that support YOUR contention that the COUNTY violated 22 CCR
§§35079-35091; 35123; 35180-35184; 35197; 35203; 35207- 35207.1; 35211 as alleged in
paragraph 69(o) of the Complaint.
SPECIAL INTERROGATORY 63:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(o) of the Complaint.
SPECIAL INTERROGATORY 64:
Please state all facts that support YOUR contention that the COUNTY violated 22 CCR
§§89227; 89231; 89318; 89372 as alleged in paragraph 69(p) of the Complaint.
SPECIAL INTERROGATORY 65:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 69(p) of the Complaint.
SPECIAL INTERROGATORY 66:
Please state all facts that support YOUR contention that the COUNTY “failed to report
T.T.’s sexual and/or physical abuse, failed to properly or adequately report it to law
enforcement, and failed to set up safeguards and/or act to remove T.T. from Ms. Spurlock’s
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home once they had notice of the sexual and/or physical abuse” as alleged in paragraph 74 of the
Complaint.
SPECIAL INTERROGATORY NO. 67:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contention in paragraph 74 of the Complaint.
SPECIAL INTERROGATORY NO. 68:
Please state all facts that support YOUR contention that the COUNTY “failed to
diligently discharge” the duties set out in paragraphs 69(a)-(e) of the Complaint and
“obligations, and that failure was a substantial factor and/or a direct proximate cause of severe
injuries caused to Plaintiff. Had Defendants complied with and/or fulfilled their mandatory
obligations T.T.’s sexual abuse would not have occurred and/or ended earlier” as alleged in
paragraph 75 of the Complaint.
SPECIAL INTERROGATORY NO. 69:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 75 of the Complaint.
SPECIAL INTERROGATORY NO. 70:
Please state all facts that support YOUR contention that the COUNTY’s “acts and/or
omissions were the proximate, legal causes of the damages sustained by Plaintiff” as alleged in
paragraph 76 of the Complaint.
SPECIAL INTERROGATORY NO. 71:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 76 of the Complaint.
SPECIAL INTERROGATORY NO. 72:
Please state all facts that support YOUR contention that “the non-entity defendants, and
each of their malicious, despicable, and/or wrongful conduct as herein alleged was intentional,
done with malice, and/or with a conscious disregard for Plaintiff’s rights” as alleged in
paragraph 77 of the Complaint.
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SPECIAL INTERROGATORY NO. 73:
Please IDENTIFY all PERSON(S) who YOU believe may have information supporting
YOUR contentions in paragraph 77 of the Complaint.
SPECIAL INTERROGATORY NO. 74:
Describe any contact YOU have had with COUNTY employees regarding the
INCIDENT referenced in the Complaint, including the name of the employee, the date of the
contact, and the substance of the communication.
SPECIAL INTERROGATORY NO. 75:
Please IDENTIFY the name, address, telephone number, dates of employment, job title,
nature of work and reason why employment ended for each employer or self-employment you
have had from the date of the INCIDENT to present.
SPECIAL INTERROGATORY NO. 76:
Please IDENTIFY the amounts of all wages, income, earnings and benefits (including but
not limited to Social Security death benefits, Aid to Families with Dependent Children, MediCal, County Health Care, Veterans Administration and private insurance) YOU received on an
annual basis for the years 2012 to present.
DATED: September 9, 2022 CLAUDIA G. SILVA, County Counse