Item 1
Answer Questions Carefully
Interrogatories
Save each item when you finish it. If you are unsure, leave it in progress and come back later.
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1 of 27 completed
Item 2
List all former names and when you were known by those names. State all addresses where you have lived for the past ten years, the dates you lived at each address, your social security number, and your date of birth.
Item 3
Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime, the date and the place of the conviction.
Item 4
Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in plaintiff's complaint, detailing as to such policies the name of the insurer, the number of the policy, the effective dates of the policy, the available limits of liability, and the name and address of the custodian of the policy.
Item 5
Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and, if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed.
Item 6
Color copies (front and back) of all driver's licenses, learner's permits, or state identification cards presently issued to J.W., as well as all such credentials issued prior to the subject incident.
Item 7
Was J.W. suffering from physical infirmity, disability, or sickness at the time of the incident described in the complaint? If so, what was the nature of the infirmity, disability, or sickness?
Item 8
Did J.W. consume any alcoholic beverages or take any drugs or medications within 24 hours before the time of the incident described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them.
Item 9
Describe in detail how the incident described in the complaint happened, including all actions taken by J.W. to prevent the incident.
Item 10
Describe in detail each act or omission on the part of any party to this lawsuit that you contend constituted negligence that was a contributing legal cause of the incident in question.
Item 11
State the facts upon which you rely for each affirmative defense in your answer.
Item 12
Do you contend any person or entity other than you is, or may be, liable in whole or part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon which your contention is based, and whether or not you have notified each such person or entity of your contention.
Item 13
Were you or J.W. charged with any violation of law (including any regulations or ordinances) arising out of the incident described in the complaint? If so, what was the nature of the charge; what plea or answer, if any, did you enter to the charge; what court or agency heard the charge; was any written report prepared by anyone regarding the charge, and, if so, what is the name and address of the person or entity who prepared the report; do you have a copy of the report; and was the testimony at any trial, hearing, or other proceeding on the charge recorded in any manner, and, if so, what is the name and address of the person who recorded the testimony?
Item 14
Describe the driving conditions at the time of the incident described in the complaint, including the weather, road condition, lighting conditions, and visibility.
Item 15
At what approximate speed was the golf cart traveling at the time of the incident described in the complaint?
Item 16
Describe in detail all actions J.W. took when approaching the pathway exit onto Wyland Court, including whether he slowed down, applied brakes, or took any other measures.
Item 17
Had you or J.W. been on or about the location where the incident allegedly took place prior to the date of the incident, and, if so, on how many occasions and for what purpose?
Item 18
At the time of the incident described in the complaint, did J.W. have permission to drive the golf cart? If so, state the names and addresses of all persons who gave such permission and describe how the permission was granted.
Item 19
Describe any and all training, instruction, or experience J.W. had received regarding the safe operation of golf carts or similar vehicles prior to the date of the incident described in the complaint, including the date, location, and name of the person or entity who provided such training or instruction.
Item 20
Was J.W. or yourself familiar with the rules, regulations, or policies of Keene's Pointe Community Association regarding golf cart operation at the time of the incident described in the complaint? If so, describe in detail your respective knowledge of such rules, regulations, or policies, and state how you obtained such knowledge.
Item 21
Was J.W. interacting with any communications or entertainment device (such as a cell phone, two-way radio, music player, tablet, or e-reader) in any way at the time of the incident described in the complaint? If so, describe what you were doing. If you were communicating with another individual, state the name, address, and telephone number of that person. Also, state the telephone number and service provider of any cellular telephone you owned or had access to on the date of the incident, regardless of whether or not you were using it when the incident occurred.
Item 22
Did any mechanical defect in the golf cart J.W. was operating at the time of the incident described in the complaint contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident.
Item 23
Describe any and all prior experience J.W. had operating golf carts, motorized carts, all-terrain vehicles, or similar motorized vehicles, including the dates, locations, and circumstances of such operation.
Item 24
List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge.
Item 25
Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance of each statement.
Item 26
State the name and address of every person known to you, your agents, or your attorneys who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared.
Item 27