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.
Progress
2 of 28 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 (10) 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 (1) year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction.
Item 4
Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in Plaintiffs’ 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
Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident.
Item 6
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 7
State the facts upon which you rely for each affirmative defense in your Answer.
Item 8
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 9
Were you charged with any violation of law (including any regulations or ordnances) arising out of the incident described in the Complaint? If so, what was the nature of the charge; what plea or answer, if any, was entered 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 mad 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 10
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 11
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 12
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 13
Do you intend to call any expert witnesses at the trial of this case? If so, state as to each such witness the name and business address of the witness, the witness's qualifications as an expert, the subject matter upon which the witness is expected to testify, the substance of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion.
Item 14
Have you made an agreement with anyone that would limit that party's liability to anyone or any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it.
Item 15
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 16
Do you wear glasses, contact lenses, or hearing aids?
Item 17
Were you 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 18
Did you consume any alcoholic beverages or take any drugs or medications within twelve (12) 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 19
Did any mechanical defect in your motor vehicle with a large flatbed trailer in tow, towing heavy equipment, contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident.
Item 20
List the name and address of all persons, corporations or entities who were registered title owners or who had ownership interest, or right to control, the motor vehicle that you were driving at time of the incident described in the Complaint; and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number.
Item 21
List the name and address of all persons, corporations, or entities who were registered title owners or who had any ownership interest in, or right to control, the motor vehicle that you were driving at the time of the incident described in the Complaint, as well as any trailer, including a large flatbed trailer, that was in tow at the time of the incident. For each, describe the nature of the ownership interest or right to control the motor vehicle and the trailer, and describe both the vehicle and the trailer, including the make, model, year, and vehicle identification number (VIN) or serial number, if applicable.
Item 22
At the time of the incident described in the Complaint, did you have permission to drive the vehicle? If so, state the names and addresses of all persons who have such permission.
Item 23
At the time of the incident described in the Complaint, were you engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity.
Item 24
Was the motor vehicle and/or the large flatbed trailer in driving/towing at the time of the incident described in the Complaint damaged in the accident, and if so, what was the cost to repair the damage?
Item 25
At the time of this incident, please explain or identify: a. What were you doing? b. Where were you going? c. The purpose for your travel? d. Your employer, including name, address, phone number, duration, and terms of employment relationship?
Item 26
List the names, titles, and addresses of all persons who have provided information, aid, or assistance in answering any issues addressed in these interrogatory questions and give a brief summary of the information or assistance rendered by that person(s).
Item 27
Describe in complete detail the appearance of Plaintiffs immediately after Plaintiffs’ alleged occurrence, including any obvious injuries, the emotional state of Plaintiffs, whether Plaintiffs appeared in pain or otherwise.
Item 28