Legal Jury Interrogatories

JURY INTERROGATORIES

Plaintiff:    Defendant:    Case No.:

Court:    Presiding Judge:

RECITALS

WHEREAS, Plaintiff has alleged causes of action against Defendant arising out of the incident, transaction, or occurrence described in the pleadings and seeks a special verdict to resolve specific factual issues; and

WHEREAS, the Court has authority to submit written interrogatories to the jury for a special verdict or to require jury findings on ultimate or subordinate factual issues; and

WHEREAS, the parties desire to designate those interrogatories to be submitted to the jury and to set forth instructions, definitions, and procedures for answers and related document production;

NOW THEREFORE, the parties propound the following Jury Interrogatories pursuant to the applicable rules of civil procedure and the Court's authority to obtain a special verdict. The party required to answer shall provide written answers, verified as required by law, and produce non-privileged documents responsive to requests set forth herein.

DEFINITIONS AND INSTRUCTIONS

1. Definitions: As used herein, "you" and "your" refer to the party to whom these interrogatories are directed. "Document" and "documents" mean all writings, recordings, electronic data, or tangible things within your possession, custody, or control, including copies and summaries thereof.

2. Time to Respond: Unless the Court orders otherwise, you must serve written answers and objections within the time prescribed by the rules of civil procedure for interrogatories. Answers must be signed under penalty of perjury by the person making them.

3. Objections: If you object to any interrogatory, state the specific legal and factual ground for each objection with sufficient detail to permit the propounding party and the Court to evaluate the objection. To the extent an objection is made to part of an interrogatory, respond to the remainder.

4. Claim of Privilege: If you withhold information on the ground of privilege or work product, produce a privilege log describing the nature of the withheld document, the basis for the privilege, date, author, addressee, and general subject matter sufficient to enable a determination of the claim.

5. Continuing Duty: These interrogatories are continuing. You must promptly supplement or amend any answer upon obtaining additional or different information that renders the answer incorrect or incomplete.

INTERROGATORIES

Interrogatory No. 1: State your full name, current address, and all other names by which you have been known during the five years preceding the incident.

Interrogatory No. 2: Describe in detail all facts upon which you rely to assert or deny liability, including dates, locations, names of witnesses, and the substance of each witness's anticipated testimony.

Interrogatory No. 3: Identify each document, photograph, electronically stored information, or tangible item upon which you intend to rely at trial and state the custodian or location of each item.

Responsive documents produced and Bates-stamped as:

Interrogatory No. 4: Itemize each category of damages claimed, the computation of each category, the date through which computation is made, and the supporting documents for each category of damages.

Interrogatory No. 5: Identify all medical providers, dates of treatment, and the nature of treatment sought or received related to the claims or defenses in this action.

Interrogatory No. 6: State whether any photographs, measurements, inspections, tests, or diagrams have been made concerning the subject matter of this litigation. If so, identify them and state the identity of the person who performed them.

Interrogatory No. 7: Identify each person whom you expect to call as an expert at trial, the subject matter of the expert's testimony, the expert's qualifications, and the documents or information reviewed by the expert.

Interrogatory No. 8: State whether any statement, written or recorded, was made by any party or witness relating to the subject matter of this litigation. If so, identify the statement, the person who made it, and the present location of the statement.

Interrogatory No. 9: Describe any communications between the parties or their agents pertaining to the subject matter of this action, including date, participants, and content summary.

Interrogatory No. 10: Identify any insurance agreement that may provide coverage for the claims alleged in the complaint, including insurer name, policy number, limits of liability, and applicable coverage periods.

VERIFICATION

The responding party certifies: I declare under penalty of perjury under the laws of the State of that the foregoing answers are true and correct to the best of my knowledge, information, and belief, and that I have made a diligent search and reasonable inquiry to obtain the information set forth herein.

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Jury Interrogatories and responses, including all attachments, was served on the following parties on by the following method:

MISCELLANEOUS PROVISIONS

Governing Law: This submission of interrogatories and any dispute concerning responses shall be governed by the substantive and procedural laws of the State of , without regard to its choice-of-law rules.

Entire Agreement: These interrogatories represent the full statement of the factual questions proposed to the jury by the propounding party and supersede any prior informal lists of jury questions exchanged between the parties unless expressly incorporated in writing.

Severability: If any provision of these interrogatories is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

Amendments and Waiver: These interrogatories may be amended by written agreement of the parties or by order of the Court. No waiver of any provision shall be effective unless in writing.

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