_________________ : _______ JUDICIAL DISTRICT COURT
VERSUS : PARISH OF _______ , LOUISIANA
_________________ : DOCKET NO. ____
______________________________________________________________________________
ANSWERS TO INTERROGATORIES
NOW INTO COURT, through undersigned counsel, comes _________________
Plaintiff, who answers Defendant's, _________________ , interrogatories with respect shows:
1.
Name: _________________
DOB: _______ ____ , ____
POB: _________________ , Louisiana
Marital St: _______
Address: _________________ , _________________
SSN: _______
2.
I completed _________________ .
3.
I have never been convicted of any crimes whatsoever.
4.
I was traveling on _______ and my view was blocked by a cement truck traveling in my
direction on my lane. The date of the accident was in the morning of _______ ____ , 20 ____ in
_______ , Louisiana.
5.
I have suffered severe neck pain as a result of the accident.
6.
I have not fully recovered from the injuries sustained.
7.
I still suffer a substantial amount of pain in my neck.
8.
I was admitted to _________________ on _______ ____ , 20 ____ for injuries sustained
from the accident. I am presently attending visits at _________________ , at
_________________ , ____ ____ , LA ____ .
9.
(11144) _________________
_________________
_________________ , LA ____
Intermediate Care on _______ ____ , 20 ____ and _______ ____ , 20 ____
$ ____
(2) _________________
_________________
____ ____ , LA ____
Radiology Services on _______ ____ , 20 ____ and _______ ____ , 20 ____ .
$ ____
_________________
_________________
____ ____ , LA ____
Therapy, _______ ____ , 20 ____ through present.
$ ____
10.
See Number 9 above.
11.
I am presently undergoing treatment at _________________ , _________________ ,
____ , LA ____ for the injuries sustained in this accident.
12.
From _______ ____ , 20 ____ through _______ ____ , 20 ____ , I was employed by
_________________ at $ ____ per hour and performing clerical work. From ____ to present, I
am employed with _________________ as a cashier at $ ____ per hour.
13.
On _______ ____ , 20 ____ , I was involved in an automobile accident at which time I
sustained jaw, shoulder and back pain. I received medical treatment from _________________ ,
_________________ , _________________ and _________________ . A suit was never filed in
connection to this accident.
14.
(1) Not known at this time.
(2) Not known at this time.
(3) Not known at this time.
15.
I am not claiming lost earning or loss of earnings capacity.
16.
See attached.
17.
No statements were taken from any individuals as to the nature of this accident.
18.
At this time, we are unsure of who will be called as a witness for the defense.
19.
See Number 18 above.
20.
See attached.
21.
I was driving at approximately 45 miles per hour at the time I became aware that an
accident might result.
22.
Suddenly appeared in my lane of travel, giving me no time to try to avoid an accident.
23.
Unknown.
24.
I was driving at approximately 45 miles per hour at the moment of impact.
Respectfully Submitted,
____________________________
_________________
Attorney for Plaintiff
_________________
_______ , LA ____
( ____ ) _______
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