Fill and Sign the First Plaintiff Defendant Form

IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________       ) )       ) Petitioner/Plaintiff, ) ) ) NO.       Vs. ) )       ) Respondent/Defendant ) ) FIRST SET OF INTERROGATORIES PROPOUNDED BY PLAINTIFF TO DEFENDANT The Plaintiff, _____________________, propounds the following Interrogatories to the Defendant, _____________________, to be answered in writing, under oath, and pursuant to the ___________ Rules of Civil Procedure within ___________ (___) days of service hereof. INTERROGATORIES Interrogatory No. 1: Identify each person whom you intend to call as a lay witness at the trial of this suit, and provide each such person's address and phone number. Interrogatory No. 2: State the name, address, and telephone number of each person whom you intend to call as an expert witness at the trial and, as to each, please state: a. The subject matter on which the expert is expected to testify; b. The substance of the facts and opinions to which the expert is expected to testify; c. A summary of the grounds for each opinion. Interrogatory No. 3: Identify each person who was an occurrence witness to the accident made the subject of this suit, and provide each such person’s address and phone number - 1 - Interrogatory No. 4: Describe any insurance agreement under which any insurance business may be liable to satisfy part or all of the judgment which may be entered in this action, or to indemnify or reimburse for payments made to satisfy the judgment, by stating the name of the person or entity insured, the name of the insurer, and the amount of any liability insurance coverage Interrogatory No. 5: Identify fully the year, make, model, color, and mileage of the vehicle defendant was operating at the time of the accident made the subject of this suit. Interrogatory No.6: Identify who owned the vehicle defendant was operating at the time of the accident made the subject of this suit. Interrogatory No. 7: Please state whether defendant, at the time of the accident made the subject of this suit, had a valid driver’s license, the state of issuance, any suspensions or revocations, date of issuance and expiration, type of license, and any restrictions on said license. Interrogatory No. 8: Describe in detail the manner in which you assert that the accident made the subject of this suit occurred, identifying the speed, position, direction, and location of each vehicle involved during each approach to, at the time of, and immediately after the collision. Interrogatory No. 9: Identify fully the purpose of the trip that you were making at the time of the accident made the subject of this suit. Interrogatory No. 10: With respect to your answer to interrogatory number 9, identify from what point or location and at what time you departed, and identify what your destination was and the time you were scheduled to arrive. Interrogatory No. 11: Identify the route you had followed from the time you departed on this trip to the point of the accident made the subject of this suit. - 2 - Interrogatory No. 12: Identify whether or not you made any stops prior to the accident made the subject of this suit and, if so, the time and place of each stop and what you did there. Interrogatory No. 13: State the name, address, and telephone number of each person known to you to be an eye witness to the accident made the subject of this suit. Interrogatory No. 14: State all factors or events which you believe caused or contributed to the cause of the accident made the subject of this suit. Interrogatory No. 15: If you contend the Plaintiff in any way caused or contributed to the accident, state in detail each act or omission that you contend the Plaintiff did which caused or contributed to the accident. Interrogatory No. 16: If you have ever been in an automobile accident other than the one made the subject of this suit, identify the date and place each accident occurred and the names and addresses of the drivers and passengers involved. Interrogatory No. 17: Identify each and every prescribed or non-prescribed drugs that you took within the twenty - four hour period before the accident made the subject of this suit, including the name, dosage, and time the drug was taken. Interrogatory No. 18: Identify any alcoholic beverages that you drank within the twenty - four hour period before the accident made the subject of this suit, including the type, amount, time, and place where the drinks were consumed. Respectfully submitted, Dated: Name:       Title:       Address: Address: - 3 - City, State, Zip: Phone: Fax: E-Mail: Attorney No.: CERTIFICATE OF SERVICE I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____. - 4 -