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Fill and Sign the Interrogatories 497295594 Form

Fill and Sign the Interrogatories 497295594 Form

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IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA __________________________ , Plaintiff, vs. CIVIL ACTION NO. CV-_______________ __________________________ Defendants. INTERROGATORIES TO ________________________ Comes now the Plaintiff, __________, in the above styled cause and desiring the testimony of the Defendant, _____________ propound to said Defendant the following interrogatories to be answered pursuant to Rule 33 of the Alabama Rules of Civil Procedure, to wit: 1. Please state your full and complete name, date of birth, social security number and driver  s license number. ANSWER : 2. Please explain how you contend the accident of ____________ that is made the basis of this suit occurred and, with respect to said accident, please answer the following: (a) Please state from where you had departed immediately prior to the accident of __________________ that is made the basis of this suit: ANSWER : (b) Please state your intended destination at the time of the accident of ______________ that is made the basis of this suit: ANSWER : (c) Please state the name and address of each person occupying the vehicle with you at the time of the accident of __________, ____ that is made the basis of this suit. ANSWER : (d) Please state whether or not you were wearing your seat belt at the time of the accident of __________________, ___________ that is made the basis of this suit: ANSWER: (e) Please state the make, year, model, color and body style of the vehicle you were operating at the time of the accident of March 28, 1995 that is made the basis of this suit: ANSWER : 3. Please state the substance of all conversations between yourself and ______________ at the scene of the accident that is made the basis of this suit including in your answer all statements made by ______________ regarding the accident that is made the basis of this suit: ANSWER: 4. Please state the substance of all statements overheard by you at the scene of the accident that is made the basis of this suit by ___________________________. ANSWER: 5. Please describe all damage to the vehicle you were operating at the time of the accident of ________________________, _________________ that is made the basis of this suit including in your answer a description of such damage and locate on the vehicle you were operating where such damage occurred. ANSWER: 6. Please state the name and address of each repair shop, body shop, repair person, automotive business or other person or entity who provided any estimate for repairs and/or who undertook any repairs with regard to damages allegedly sustained to the vehicle you were operating as a result of the impact of _______________________, _________________ that is made the basis of this suit: ANSWER : 7. Please state whether or not you have been involved in any other accidents before or after _____________________, _________________, including the date, the names, telephone numbers, and addresses of all persons involved, and a detailed description of the accident. ANSWER : 8. Please state whether or not you have ever been Plaintif or a Defendant in any other lawsuit and, if so, please state the nature of each such other lawsuit, the name of the Court where each such other lawsuit is or was pending, the name and address of your attorney, and the disposition of the suit. ANSWER : 9. List all moving violations you have even been cited for and explain the disposition of each. You should include any citations, whether ultimately dismissed or not. ANSWER : 10. Please state the name and address of each person known to you to have witnessed the accident of _____________________, __________ that is made the basis of this suit. ANSWER : 11. Please state the name and address of each person you expect to testify at the trial of this case as an expert witness on your behalf and state in your answer the substance of all facts and opinions to be given by each such expert witness at the trial of this case. ANSWER : 12. Please state the name and address of your employer on _______________, ______. ANSWER : 13. Please state your judgment of the speed of your vehicle operated at the time of the impact that is made the basis of this suit and also answer the following: (a) State whether or not you observed the vehicle operated by ______________ prior to the impact that is made the basis of this suit; ANSWER : (b) If you state that you observed the vehicle operated by ______________ prior to the impact that is made the basis of this suit, please state all maneuvers witnessed by you of said vehicle; ANSWER : 14. List the name and address of each person with whom you have ever discussed this accident, other than your attorney. ANSWER : 15. Have you discussed this accident with any representative at your insurance company? ANSWER : 16. Do you understand these interrogatories are to be answered under oath? ANSWER : ______________________________ Attorney for Plaintif CERTIFICATE OF SERVICE I hereby certify that I have on this the ____ day of _________, ____, served a copy of the foregoing upon ______________________________, ____________, Alabama, _____________ by placing same in United States mail, properly addressed frst class postage prepaid.

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