Fill and Sign the Dane Thomas Vs State of Louisiana the Department of Form

_______________ , : ________ JUDICIAL DISTRICT COURT ET VIR : DOCKET NO. ____ VERSUS : PARISH OF ________ _______________ , : STATE OF LOUISIANA ______________________________________________________________________________ ANSWERS TO INTERROGATORIES NOW INTO COURT, through undersigned counsel, co mes _______________ , Plaintiff, who answers Defen dant's, _______________ , interrogatories with respect shows: 1. Plaintiff's full nam e is _______________ (________ ), Post Office Box ________ , _______________ , _______________ , Louisiana, ________ . Social Security No. ________ and Plaintiff is married. 2. Plaintiff has a _______________ degree from _________ ______ , 20 ____ ; _______________ . 3. A. (1) _______________ , _______________ , Louisiana, ________ ; (2) _______________ of _______________ (self -employed). B. See answer to A -1. C. Approximately $ ____ pe r hour from ________ , part time employment. 4. Plaintiff contends that she has lost time since the date of this accident from her job of Hair Weaving due to the fact that she is unable to sit or stand for times required to perform said service s. Each client that Plaintiff is unable to service as a ________ costs her anywhere from $ ____ to $ ____ per client. 5. Plaintiff has not been involved in any accident either prior to or subsequent to this incident. 6. On ________ ____ , 20 ____ , Plaintiff slipped and fell at _______________ . As a result of this slip and fall, Plaintiff landed on her buttocks. Plaintiff suf fers from lower back pain and pain in her SI joint as a result of the injury sustained and embarrassment as a result of slip and fall. Plaintiff also suffers from sleeplessness because of pain. 7. Plaintiff has been treated at the following medical faci lities or by the following medical practitioners: 1. ________ Hospital , _______________ , ________ , Louisiana ____ , Phone No. ________ . 2. ________ Center, _______________ , ________ , Louisiana, ____ , Phone No. ________ . 3. Dr. ________ , __________ _____ , ________ , Louisiana , Phone No. ________ . Medical Testimony. 4. Dr. ________ , Phone No. ________ . Medical Testimony. 5. Dr. ________ , _______________ , ________ , Louisiana , Phone No. ________ . Medical Testimony. 6. Dr. ________ , _______________ , ____ , Louisiana , Phone No. ________ . Medical Testimony. 7. Dr. ________ , _______________ , ________ , Louisiana , Phone No. ________ . Medical Testimony. 8. ________ , Physical Therapist, _______________ , ________ , Louisiana , Phone No. ________ . Medical Testimony. 9. ________ , PT, _______________ , ________ , ________ , Louisiana. Medical Testimony. 10. ________ , M.D., _______________ , _____ ___ , Louisiana. 8. Plaintiff had no problems pr ior to this accident. 9. Plaintiff is still receiving medical s ervices from Dr. ________ , Psychiatrist, date of la st tre atment was ________ ____ , 20 ____ . She is also receiving medical services from Dr. ________ , date of la st treatment was ________ ____ , 20 ____ , and is soon scheduling sur gery with Dr. ________ . 10. Plaintiff is currently receiving medical treatment for the injuries suffered. 11. Plaintiff has provided all names o f Docto rs or Medical Practitioners by whom she has been treated . 12. Within the last ten (10) years, Plaintiff has b een treated by Dr. ________ , _______________ , ________ , Louisiana, ________ , Phone No. ________ . 13. Plaintiff had no illness, sickness or disease prior to this incident. Plaintiff has had cosmetic surgery prior to this incident. 14. Plaintiff has never been convicted of any crime. 15. Amount is undeterminable at this time. 16. Plaintiff's answer to Interrogatory 16 as follows: A. The host, ________ (last name unkn own), at _______________ ; ________ . B. The man ager at _______________ (name unknown). C. ________ , ________ . D. Attorney _______________ has exhibits that will be introduced at the trial. E. Plaintiff has not obtained the services of an expert at this point, but will so advise counsel for Defendant if and when an expert is obtained. 17. There have been no recorded or written statements obtained by Plaintiff or attorneys for Plaintiff. 18. Plaintiff, _______________ , spoke with the maitre d’ of _______________ , and the manager of same but took no recorded statements. 19. See answers to Interrogatory No. 7. 20. A. All medical witnesses will testify as to their medical findings as it pertains to Plaintiff, _______________ and _______________ (last name unknown), maitre d’ at _____________ __ , and _______________ , will testify as to facts relative to the incident in question. 21. Any and all medical records including receipts of medical bills. Respectfully Submitte d, ____________________________ _______________ Attorney for Plaintiff _______________ ________ , LA ____ (____ )________ _____________________________ _______________ Attorney for Plaintiff _______________ ________ , LA ____ (____ )________ LA. Bar Roll No. ____ CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the above and foregoing has been forwarded by U.S. Mail, postage prepaid, and correctly addressed to opposing counsel of record. _______________ , Louisiana, this ______ day of __________________ _, 20 ____ . ___________________________ _______________ ___________________________ _______________