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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