Fill and Sign the Case Trial Packet Louisiana Form

[Note: Selection of the proper form and its use and modification to suit individual facts and circumstances requires careful review of all the language by the user.] Form 20.1. Notice of Deposition * * * (suit caption) * * * NOTICE OF DEPOSITION You are notified that the plaintiff in the above - captioned case will take the deposition of: ______________________________ ( name ) ________________________________________ ( address ) on the _____ day of _______________ , 20 _____ , _____ A.M. at the office of _______________ , located at ____________________ , _______________ , Louisiana, before an officer authorized to administer oaths. Attorney at Law (address) (phone number) CERTIFICATE OF SERVICE I certify that a copy of this notice of deposition was mailed to _______________ , attorney for the defendant, on the _____ day of ____________________ , 20 _____ . (attorney signature) Form No. 20.2 Letter Requesting Issuance of Subpoena for Deposition (date) Clerk of Court _____ Judicial District Court P. O. Box _______________ , Louisiana, Re: ____________________ v. ____________________ , No. __________ Div. __________ Dear Sir: Please cause a subpoena to be served on __________ to appear and answer questions at a deposition to be held on the _____ day of _______________ , 20 _____ , at _____ P.M. at __________ , _______________ , Louisiana. A copy of the notice of deposition is enclosed. Please serve the witness at her domicile at __________ or at her place of employment located at ______________________________ . Enclosed is my check in the amount of $ _________ to cover the costs. Sincerely, Attorney at Law enclosure Form No. 20.3 Interrogatories * * * (caption) * * * INTERROGATORIES TO: (name of party) THROUGH: (name and address of attorney for party) You are hereby notified that the defendant in the above - captioned matter, pursuant to Code of Civil Procedure Articles 1457 and 1458, propounds the following interrogatories upon the plaintiff. The following interrogatories should be answered by the plaintiff separately and fully under oath within fifteen (15) days after service. These interrogatories should be supplemented or amended as required by LSAC.C.P. art. Article 1428. INTERROGATORY NO. 1 CERTIFICATE OF SERVICE I certify that a copy of these interrogatories was mailed to ____________________ , attorney for the plaintiff, on the _____ day of ____________________ , 20 _____ . _____________________________ ( Attorney signature ) Form No. 20.4 Response to Interrogatories * * * (caption) * * * ANSWERS TO INTERROGATORIES TO: (name of party) THROUGH: (name and address of attorney for party) You are hereby notified that the plaintiff, pursuant to Louisiana Code of Civil Procedure Articles 1457 and 1458, serves these answers to the interrogatories of the defendant, as follows: Answer to Interrogatory No. 1 _______________________ ( Party’s signature ) SWORN TO AND SUBSCRIBED, before me this _____ day of _______________ , 20 _____ . Notary Public CERTIFICATE OF SERVICE I certify that a copy of these answers to the interrogatories was mailed to ____________________ , attorney for the defendant, on the _____ day of _______________ , 20 _____ . _________________________ ( Attorney signature ) Form No. 20.5 Letter Giving Notice of Intention to File Motion to Compel __________ ( Date ) Attorney for Plaintiff ________________________________________ P. O. Box ________________________________________ (city) , Louisiana, (zip code) Re: ____________________ v. ____________________ , No. __________ Div. __________ Dear Sir: Interrogatories were served on you on the _____ day of _______________ , 20 _____ to be answered by your client. More than fifteen days have elapsed and I have not received your answers or objections. Enclosed is another copy of the interrogatories. Please have your client answer them promptly. If I do not receive the answers within fifteen days, I will file a motion to compel answers to these interrogatories. Alternative paragraph I have received your answers and objections to plaintiff's interrogatories. The objection made to Interrogatory No. is unjustified because ________________________________________ . If you do not give a full and complete answer to this interrogatory within fifteen days, I will file a motion to compel. Sincerely, Attorney at Law enclosure certified mail Form No. 20.6 Motion to Compel Answers to Interrogatories. * * * ( caption )* * * MOTION TO COMPEL ANSWERS TO INTERROGATORIES On motion of ____________________ , plaintiff, through undersigned counsel and upon suggesting to the Court that: 1. Made defendant is ____________________ , who is domiciled in this parish. 2. Plaintiff served defendant with interrogatories on the _____ day of _______________ , 20 _____ , as appears from the certificate of service of plaintiff's interrogatories filed in the record of this case. A copy of the interrogatories is attached to this motion. Plaintiff then mailed opposing counsel a letter-dated __________ , 20 _____ , a copy of which is attached to this motion. In that letter, notice was given to opposing counsel that a motion to compel would be filed if the interrogatories were not answered within a reasonable time. 3. Defendant has failed to answer or object to the interrogatories at the time this motion was filed. [Or] The answers to Interrogatory Numbers 1 and 2 are not sufficient because ______________________________ . 4. Plaintiff is entitled to have the information requested in the interrogatories. WHEREFORE, mover prays that a rule to show cause issue to show cause why the defendant should not be compelled to answer the attached interrogatories, and be ordered to pay the expenses, including attorney fees, associated with filing this motion. * * * (caption) * * * ORDER Upon consideration of the foregoing motion: IT IS ORDERED that ____________________ show cause on the _____ day of _______________ , 20 _____ why the defendant should not be compelled to answer the attached interrogatories, and be ordered to pay expenses, including attorney fees, associated with filing this motion. RENDERED AND SIGNED, this _____ day of _______________ , 20 _____ , in _______________ , Louisiana, Judge Form No. 20.7 Order Compelling Answers to Interrogatories and Awarding Expenses. * * * (caption) * * * This matter was heard on the _____ day of _______________ , 20 _____ pursuant to regular assignment. Present in court were: ____________________ , attorney for plaintiff and _______________ , attorney for defendant. The Court, upon considering the motion to compel answers to interrogatories, and after hearing the arguments of counsel, and finding that plaintiff is entitled to the relief sought and that defendant's opposition was not substantially justified: IT IS ORDERED that defendant, ____________________ , serve upon the plaintiff answers to the interrogatories propounded by plaintiff within _____ days from the signing of this order. IT IS FURTHER ORDERED that defendant pay the sum of $ _________ to plaintiff as expenses and attorney fees incurred in preparing this motion and order. ORDERED AND SIGNED this _____ day of _______________ , 20 _____ . Judge Form No. 20.8 Order Refusing to Compel Answers to Interrogatories and Awarding Expenses. * * * (caption) * * * This matter was heard on the _____ day of _______________ , 20 _____ pursuant to regular assignment. Present in court were: __________ , attorney for plaintiff and ____________________ , attorney for defendant. The Court, upon considering the motion to compel answers to interrogatories served on defendant, and after hearing the arguments of counsel, and upon finding that plaintiff is not entitled to the relief prayed for and that plaintiff's motion to compel was not substantially justified: IT IS ORDERED that plaintiff's motion to compel answers to interrogatories is denied and the plaintiff is prohibited from discovery of the following information: __________ . IT IS FURTHER ORDERED that plaintiff pay the sum of $ _________ to defendant as expenses and attorney fees incurred by him in opposing plaintiff's motion. ORDERED AND SIGNED this _____ day of _______________ , 20 _____ . Judge Form No. 20.9 Request for Admissions. * * * (caption) * * * REQUEST FOR ADMISSIONS TO: (name of party) THROUGH: (name and address of attorney for party) You are hereby notified that the plaintiff in the above - captioned matter, pursuant to Code of Civil Procedure Articles 1466 and 1467, serves the following requests for admissions upon the defendant. The following matters should be admitted or denied by the plaintiff within fifteen (15) days after service. REQUEST FOR ADMISSION NO. 1 REQUEST FOR ADMISSION NO. 2 Submitted by Attorney: ______________________________ ________________________________________ ( name and address ) CERTIFICATE OF SERVICE I certify that a copy of the foregoing request for admissions was mailed to ____________________ , attorney for the defendant, on the _____ day of _______________ , 20 _____ . ______________________________ ( attorney signature ) Form No. 20.10 Answers and Objections to Request for Admission of Facts. * * * (caption) * * * ANSWERS AND OBJECTIONS TO REQUEST FOR ADMISSIONS TO: (name of party) THROUGH: (name and address of attorney for party) You are hereby notified that the defendant in the above - captioned matter, pursuant to Code of Civil Procedure Article 1467, serves the following answers and objections to plaintiff's requests for admissions. REQUEST FOR ADMISSION NO. 1 Defendant admits that ____________________ . REQUEST FOR ADMISSION NO. 2 Defendant denies the fact in Request for Admission No. 1. Defendant denies that ____________________ . REQUEST FOR ADMISSION NO. 3 Defendant lacks information or knowledge to admit or deny Request for Admission No. 3. Defendant has made reasonable inquiry as to the matter and the information known or readily obtainable by him is insufficient to enable him to admit or deny the request. Defendant cannot answer because ______________________________ . REQUEST FOR ADMISSION NO. 4 Defendant objects to plaintiff's Request for Admission No. 4 for the following reason: ______________________________ . _________________________________ ( signature of party or attorney ) _________________ ( date ) CERTIFICATE OF SERVICE I certify that a copy of these answers and objections to the requests for admissions to was mailed to _______________ , attorney for the plaintiff, on the _____ day of _______________ , 20 _____ . ________________________________ ( attorney signature ) Form No. 20.11 Request for Production of Documents. * * * (caption) * * * REQUEST FOR PRODUCTION OF DOCUMENTS TO: (name of party) THROUGH: (name and address of attorney for party) NOTICE is given that the plaintiff, pursuant to Louisiana Code of Civil Procedure Articles 1461 and 1462, requests that the defendant produce at the office of the undersigned attorney for the plaintiff, on the _____ day of _______________ , 20 _____ at _____ A.M. , the documents designated below, for the purpose of inspecting and copying the documents. In lieu of producing the originals of the documents requested, the defendant may provide true and clear copies of the same before the designated date. This request includes all documents within your possession, custody or control. This request for production of documents should be supplemented or amended as required by LSAC.C.P. art. Article 1428. REQUEST FOR PRODUCTION NO. 1. CERTIFICATE OF SERVICE I certify that a copy of these interrogatories was mailed to ____________________ , attorney for the plaintiff, on the _____ day of _______________ , 20 _____ . ________________________________ ( attorney signature )